One option would be to just apply all of the GloBE rules with changes for the income inclusion rule
(IIR) and under-taxed payments rule
(UTPR) (as the IIR and UTPR mainly apply to the income of foreign constituent entities, whereas a QDMTT applies to domestic constituent entities).
However, it is beneficial to adapt the design of the QDMTT to reflect the domestic tax regime as otherwise this could exacerbate the complexity of a QDMTT and include provisions that aren’t even relevant to the jurisdiction (eg the stock-based compensation election
, that would not be relevant if the jurisdiction did not allow companies to deduct the value of stock-based compensation based on the market value of the stock.)