Article 36 - Reductions in Covered Taxes

Reductions in the Covered Taxes of the CE for the Tax Period are calculated as the sum of the following items:

1. The current tax expense amount related to income excluded from the GloBE income or loss calculation under Chapter 3 of these ERs;

2. Any balance or refund related to a Non-QRTC or a non-Marketable Transferable Tax Credit not recorded as a reduction in current tax expense;

3. Any amount of covered taxes treated as a balance or refunded, except for QRTCs and Marketable Transferable Tax Credits, not treated as an adjustment in current tax expense in the financial accounts;

4. The current tax expense related to an uncertain tax position;

5. Any current tax expense amount not expected to be paid within three Tax Periods from the last day of the Tax Period;

6. Any amount received by the issuer of a non-marketable, transferable tax credit in exchange for that credit;

7. Any excess received by the purchaser over the face value of a non-Marketable, Transferable Tax Credit beyond the purchase price proportionate to the amount used to settle a Covered Tax liability;

8. Any gains received by the purchaser as a result of the transfer of a non-Marketable, Transferable Tax Credit, provided the transfer occurs during the relevant Tax Period.

   Any tax credit other than a QRTC or a Marketable, Transferable Tax Credit is treated as a reduction in Covered Taxes to the extent that it is used to offset the CE’s Covered Tax liability for the Tax Period.