Taxation (Multinational - Global and Domestic Minimum Tax) Rules 2024
The International Shipping Income of a Constituent Entity of an MNE Group for a Fiscal Year is: (a) the Constituent Entity ' s International Shipping Income Revenue for the Fiscal Year (see subsection (2) );
reduced by:
(b) the Constituent Entity ' s International Shipping Income Costs for the Fiscal Year (see subsection (3) ).3-225(2)
The International Shipping Income Revenue of a Constituent Entity of an MNE Group for a Fiscal Year means the revenue obtained by the Constituent Entity for the Fiscal Year from the following activities (each of which is an International Shipping Activity ): (a) transporting passengers or cargo by a ship that it operates in international traffic, whether the ship is owned, leased or otherwise at its disposal; (b) transporting passengers or cargo by a ship operated in international traffic under slot-chartering arrangements; (c) leasing a ship, to be used for transporting passengers or cargo in international traffic, on charter fully equipped, crewed and supplied; (d) leasing a ship on a bareboat charter basis, for transporting passengers or cargo in international traffic, to another Constituent Entity of the MNE Group; (e) participating in a pool, a joint business or an international operating agency for transporting passengers or cargo by a ship in international traffic; (f) if a ship is used for transporting passengers or cargo in international traffic and has been held for use by the Constituent Entity for at least 1 year - selling the ship.
3-225(3)
The International Shipping Income Costs of a Constituent Entity of an MNE Group for a Fiscal Year means the amount computed in accordance with the following formula:
where:
direct costs
is the total costs incurred by the Constituent Entity for the Fiscal Year that are directly attributable to the Constituent Entity
'
s performance of International Shipping Activities.
indirect costs
is the total costs incurred by the Constituent Entity for the Fiscal Year that are indirectly attributable to the Constituent Entity
'
s performance of International Shipping Activities.
shipping revenue
is the Constituent Entity
'
s International Shipping Income Revenue for the Fiscal Year.
total revenue
is the Constituent Entity
'
s total revenue for the Fiscal Year.
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