Article 8 details the formula for calculating the Effective Tax Rate (ETR) for Constituent Entities within the Kingdom. The ETR is determined by dividing the aggregate Adjusted Covered Taxes by the Net Constituent Entity Income for all members of the same MNE Group located in Bahrain. Pursuant to Paragraph C, Adjusted Covered Taxes and income from investment entities are excluded from this specific calculation. Stateless Constituent Entities must calculate their ETR separately. The Regulations will provide additional controls for minority-owned entities and multi-parented groups, maintaining consistency with the OECD Pillar Two Model Rules and providing a transparent mechanism for top-up tax assessment.