Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024

CHAPTER 3 - COMPUTATION OF GloBE INCOME OR LOSS  

PART 3-3 - INTERNATIONAL SHIPPING INCOME EXCLUSION  

SECTION 3-220   ADJUSTMENT - CERTAIN SHIPPING INCOME  

3-220(1)    
In computing a Constituent Entity ' s GloBE Income or Loss for a Fiscal Year, adjust the Constituent Entity ' s Financial Accounting Net Income or Loss for the Fiscal Year so as to exclude the following amounts:

(a)    the Constituent Entity ' s International Shipping Income for the Fiscal Year;

(b)    the Constituent Entity ' s Qualified Ancillary International Shipping Income for the Fiscal Year.

3-220(2)    
However, subsection (1) does not apply if, during the Fiscal Year:

(a)    a part of the Constituent Entity ' s International Shipping Income for the Fiscal Year arises from activities involving a ship; and

(b)    the strategic or commercial management of the ship is not effectively carried on from within the jurisdiction in which the Constituent Entity is located.