GloBE Rules Series

ITQ G-

151

November 28, 2025

Question

ACo is a Constituent Entity in an MNE Group which is “within scope” of the GloBE rules.

In a particular year, ACo derives (1) International Shipping Income of 200, (2) Qualified Ancillary International Shipping Income of 120, and (3) other income (net of allocated costs) of 80.

Based on this information, what is ACo’s GloBE Income or Loss?

Answer

Before applying Art. 3.3, ACo’s GloBE Income would be 200 + 120 + 80 = 400.

Art. 3.3.1: International Shipping Income (ISI) is excluded from GloBE Income – thus, 200 reduction.

Art. 3.3.1: Qualified Ancillary International Shipping Income (QAISI) (120) is also excluded from GloBE Income. However, Art. 3.3.4 applies a cap on QAISI – i.e., QAISI cannot exceed 50% of ISI. Therefore, the final QAISI amount excluded from GloBE Income is 200 x 50% = 100.

Thus, final GloBE Income = 400 – 200 – 100 = 100.

Do you agree?

ITQ Disclaimer

This International Tax Quiz (ITQ) contains general information only, and none of International Insights Pte Ltd, its employees or directors is, by means of this ITQ, rendering professional advice or services. You use the content of this ITQ strictly at your own risk. You should not rely on all or any part of the content of this ITQ in making decisions to take action (including inaction) in regard to tax or other matters. Before making any decision or taking any action (including inaction) that may affect your tax position, your finances or your business, you should consult a qualified professional advisor. None of International Insights Pte Ltd, its employees or directors shall be responsible for any loss whatsoever sustained by any person who relies on the content of this ITQ.