7‑95 Allocable Share of Top‑up Tax of In7‑95 Allocable Share of Top‑up Tax of Investment Entity

7‑95 Allocable Share of Top‑up Tax of Investment Entity

(1) Section 2‑10 does not apply for the purposes of computing a Parent Entity’s Allocable Share of the Top‑up Tax of an Investment Entity for a Fiscal Year. (2) Instead, that Allocable Share is an amount equal to: (a) the Top‑up Tax of the Investment Entity for the Fiscal Year; multiplied by: (b) the fraction that is: (i) the Inclusion Ratio of the Parent Entity for the Investment Entity for the Fiscal Year, computed on the assumption that all Ownership Interests in the Investment Entity not held by the Parent Entity were held by owners that are not Group Entities of the MNE Group; divided by: (ii) the Inclusion Ratio of the Parent Entity for the Investment Entity for the Fiscal Year. (3) In computing the fraction mentioned in subsection (2), treat the Investment Entities as: (a) Low‑Taxed Constituent Entities; and (b) the only Constituent Entities of the MNE Group. (4) For the purposes of this section: (a) treat references in section 2‑15 to GloBE Income as references to GloBE Income or Loss; and (b) treat the reference in paragraph 2‑15(2)(a) to net income as a reference to net income or loss.