Computing the rate
For ordinary constituent entities, ETR divides their combined adjusted covered taxes by their combined GloBE income or loss. Investment entities, minority-owned groupings, stateless entities and joint ventures require separate calculations; entities in one country are not necessarily all blended together. The top-up percentage is 15% less ETR, floored at zero. Excess profits reduce GloBE income by the applicable substance-based exclusion, also floored at zero.
Additional amounts and losses
The jurisdictional amount applies the top-up percentage to excess profits, adds additional current top-up amounts and deducts QDMTT under the prescribed rules. Loss years and negative covered taxes have separate mechanics, including negative-tax carry-forward rather than an ordinary positive-income ratio. Recalculations of prior years can produce a current additional amount. Preserve the income, tax and exclusion bridges and identify the relevant case before using a formula; a jurisdictional statutory tax rate above 15% does not itself establish the computed ETR.
Official source
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