4‑15 Meaning of Additions to Covered Tax

4‑15 Meaning of Additions to Covered Taxes

The Additions to Covered Taxes for a Fiscal Year of a Constituent Entity of an MNE Group is the sum of the following: (a) the amount (if any) of Covered Taxes of the Constituent Entity for the Fiscal Year accrued as an expense in the profit before taxation in the Constituent Entity’s financial accounts for the Fiscal Year; (b) if: (i) there is a GloBE Loss Deferred Tax Asset of the MNE Group for the jurisdiction in which the Constituent Entity is located; and (ii) an amount of that GloBE Loss Deferred Tax Asset is used for the Fiscal Year under subsection 4‑125(2); and (iii) if there is a GloBE Loss Deferred Tax Asset of the Ultimate Parent Entity of the MNE Group—the Constituent Entity is not the Ultimate Parent Entity; the Constituent Entity’s share of that amount, computed based on the Constituent Entity’s share of the MNE Group’s Net GloBE Income for the Fiscal Year; (c) if: (i) the Constituent Entity is the Ultimate Parent Entity of the MNE Group; and (ii) there is a GloBE Loss Deferred Tax Asset of the Ultimate Parent Entity; and (iii) an amount of that GloBE Loss Deferred Tax Asset is used for the Fiscal Year under subsection 4‑135(2); that amount; (d) the amount (if any) of Covered Taxes of the Constituent Entity for the Fiscal Year that is paid in the Fiscal Year, to the extent that the amount: (i) relates to an uncertain tax position; and (ii) was treated as a Reduction to Covered Taxes of the Constituent Entity for a previous Fiscal Year under paragraph 4‑20(1)(e); (e) the amount (if any) of credit or refund, in respect of a Qualified Refundable Tax Credit or Marketable Transferable Tax Credit, that is recorded as a reduction, in respect of Covered Taxes, to its Accrued Current Covered Tax Expense for the Fiscal Year.