Ministerial Decision No. 55 of 2025, under the DMTT Law, specifies the rules for addressing temporary tax differences in Article 38. This article establishes the methodology for calculating the Total Deferred Tax Adjustment Amount, a key component of Adjusted Covered Taxes. It requires recasting deferred tax expenses to the 15% minimum rate if the domestic rate is higher and excludes items like uncertain tax positions. Crucially, it introduces a five-year recapture rule for unpaid Deferred Tax Liabilities (DTLs), mandating a recalculation of a prior year's Top-up Tax, aligning with OECD GloBE model rules.