The Department shall certify to the taxpayer or the business entity the amount of the credit approved by the Department for the business entity. The Department shall issue the certification, in a form approved by the Secretary, by December 15 of the calendar year following the end of the taxable year in which the Maryland qualified research and development expenses were incurred. If the total amount of the credits applied for by all business entities exceeds the maximum credit amounts available under Regulation .06 of this chapter, then the Department shall approve a credit for each business entity in an amount equal to the product of multiplying the credit applied for by the business entity times a fraction: The numerator of which is the maximum specified under Regulation .06 of this chapter; and The denominator of which is the total of all credits applied for by all business entities in the calendar year. The determination of the Department to grant or to deny an application for a certificate is final.