2‑70 Distribution of allocated Total UTP2‑70 Distribution of allocated Total UTPR Top‑Up Tax Amount to Australian Constituent Entity

2‑70 Distribution of allocated Total UTPR Top‑Up Tax Amount to Australian Constituent Entity

(1) For the purposes of this instrument, the amount of the Total UTPR Top‑up Tax Amount for an MNE Group for a Fiscal Year that is allocated to Australia under section 2‑60 (the Australian allocated amount) is distributed, in accordance with this section, to the Constituent Entities of the MNE Group that are located in Australia. (2) The amount of the Australian allocated amount distributed to a Constituent Entity of the MNE Group that is located in Australia is: (a) the Australian allocated amount; multiplied by: (b) the percentage computed under the formula in subsection (3). (3) The formula is as follows: Start formula open bracket 50% times start fraction Number of employees of CE in Australia over Number of employees of all CEs in Australia end fraction close bracket plus open bracket 50% times start fraction Total value of tangible assets of CE in Australia over Total value of tangible assets of all CEs in Australia end fraction close bracket end formula where:

Number of employees of all CEs in Australia means the total number of employees of all Constituent Entities of the MNE Group located in Australia.

Number of employees of CE in Australia means the total number of employees of the Constituent Entity located in Australia.

Total value of tangible assets of all CEs in Australia means the sum of the Net Book Value of tangible assets for the Fiscal Year of all Constituent Entities of the MNE Group located in Australia.

Total value of tangible assets of CE in Australia means the sum of the Net Book Value of tangible assets for the Fiscal Year of the Constituent Entity located in Australia.