Taxes Consolidation Act 1997 section 111Q

International shipping income exclusion

Section 111Q provides for the exclusion of international shipping income and qualified ancillary international shipping income from the calculation of a constituent entity's qualifying income or loss under the GloBE Rules.

• International shipping income covers the net income from transporting passengers or cargo by ship in international traffic, chartering ships, participating in shipping pools, and selling ships held for at least one year — provided the transport is not via inland waterways within the same jurisdiction.
• Qualified ancillary international shipping income includes net income from related activities such as short-term ship leasing, container leasing and storage, ticket sales for domestic legs of international voyages, and support services — as well as investment income integral to the shipping business.
• Both international shipping income and qualified ancillary international shipping income (including any losses) are excluded from the constituent entity's qualifying income or loss, provided the strategic or commercial management of all ships is effectively carried on from within the jurisdiction where the entity is located.
• The total qualified ancillary international shipping income of all constituent entities in a jurisdiction is capped at 50% of their combined international shipping income, and all direct and indirect costs attributed to these activities are likewise excluded from the qualifying income or loss calculation.

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