Amount on which Excess Tax in home country charged?

Sir, i am having confusing on the amount on which excess tax of home country is to be charged??
e.g. if 75% of After tax profits of a subsidiary are to be remitted as dividends and the tax rate in foreign country is 22% ..Profit before tax of foreign subsidiary is $5400………………
Tax rate in home country is 28%….
Please illustrate with a suitable format highlighting the amount on which xcess tax in home country charged..
2nd thing i want to know is the amount of dividends to be remitted should be net of with holding tax or not?
Thanx in advance..