Article 28 - Covered Taxes

For the purposes of applying the provisions of Paragraph A of Article 7 of the Law, Covered Taxes shall not include any of the following amounts:

1. Taxes accrued by a Parent Entity under a Qualified Income Inclusion Rule (IIR).

2. Taxes accrued by a Constituent Entity under a Qualified Domestic Minimum Top-Up Tax.

3. Taxes attributable to an adjustment made by a Constituent Entity as a result of the application of a Qualified Undertaxed Payments Rule (UTPR).

4. A Disqualified Refundable Imputation Tax.

5. Taxes paid by an insurance company in respect of returns to policyholders.

6. Tax imposed under the Law.

Covered Taxes in respect of any net gain or loss arising from the disposal of immovable property located in the Kingdom in the Fiscal Year for which the election under Paragraph A of Article 17 of these Regulations is made shall be excluded from the computation of Covered Taxes.