Article 9 establishes the definitive formula for computing the Domestic Minimum Top-Up Tax due in Bahrain. When the Effective Tax Rate falls below the 15% Minimum Rate, an Additional Tax Rate is applied to the Taxable Income. Taxable Income is calculated by subtracting the Substance-based Income Exclusion from the Net Constituent Entity Income, as per Paragraph B. The final Tax Due includes the product of the Additional Tax Rate and Taxable Income, plus any Additional Current Tax or Additional Tax for Permanent Differences. Filing Constituent Entities may elect annually to waive the substance-based exclusion, providing flexibility in their Pillar Two compliance strategy.