4.2.1. Covered Taxes means:
(a) Taxes recorded in the financial accounts of a Constituent Entity with respect to its income or profits or its share of the income or profits of a Constituent Entity in which it owns an Ownership Interest;
(b) Taxes on distributed profits, deemed profit distributions, and non-business expenses imposed under an Eligible Distribution Tax System;
(c) Taxes imposed in lieu of a generally applicable corporate income tax; and
(d) Taxes levied by reference to retained earnings and corporate equity, including a Tax on multiple components based on income and equity.
4.2.2. Covered Taxes does not include any amount of:
(a)Top-up Tax accrued by a Parent Entity under a Qualified IIR;
(b) Top-up Tax accrued by a Constituent Entity under a Qualified Domestic Minimum Top-Up Tax;
(c) Taxes attributable to an adjustment made by a Constituent Entity as a result of the application of a Qualified UTPR;
(d) A Disqualified Refundable Imputation Tax;
(e) Taxes paid by an insurance company in respect of returns to policyholders.