Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024
3‑220 Adjustment—certain shipping income3‑220 Adjustment—certain shipping income
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3‑220 Adjustment—certain shipping income
(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. (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.