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1. Start with current tax expense: 25,000 (Art. 4.1.1).

2. Country B royalty withholding tax (recorded as debit to royalty income): addition (Art. 4.1.2(a)). Thus, add 100. 

3. Country C digital services tax (recorded as debit to sales revenue) – If the DST is levied on gross revenue, if it's a final tax, and if it is not in substitution for corporate income tax on net income (e.g., corporate income tax does not apply to the relevant gross revenue, possibly because of source rules), then (according to the October 2020 blueprint report – we don't have the Commentary yet!), the "in lieu of" test in Art. 4.2.1(c) is not satisfied. In that situation, the DST is not a Covered Tax. For the purpose of the calculation, I will assume (for the above reasons) that the Country C DST is not a Covered Tax. Thus, ignore. 

4. Current tax expense in regard to uncertain tax positions. a. Accrued during current year (1,000): reduction (Art. 4.1.3(d). b. Paid during current year (accrued in prior year) (1,500): addition (Art. 4.1.2(c)). c. Reversed during current year (accrued in prior year) (800): ignore – because the "paid" condition in Art. 4.1.2(c) is not satisfied (but see my question below). Thus, add 500 (i.e., add 1,500 and deduct 1,000). 

5. Income tax credit (refundable in cash for 3 years): credited to current tax expense (300): addition (Art. 4.1.2(d)). Thus, add 300. 

6. Current tax expense in regard to “Excluded Dividends” (1,200): reduction (Art. 4.1.3(a)). Thus, deduct 1,200.. Thus, ACo's Adjusted Covered Taxes = 25,000 + 100 + 500 + 300 – 1,200 = 24,700 

Do you agree with ignoring the reversal in the current tax expense in regard to uncertain tax positions?