Article 5 provides the fundamental formulas for calculating the Jurisdictional Effective Tax Rate (ETR) and the resulting Top-up Tax. It introduces the Substance-based Income Exclusion (SBIE), which reduces excess profit based on payroll costs and tangible asset values. The article outlines how Top-up Tax is allocated among Constituent Entities and defines the 'de minimis' exclusion for groups with low revenue and income in the UAE. It also treats minority-owned entities as separate subgroups for ETR purposes, ensuring precise calculation of the global minimum tax impact within the UAE jurisdiction.