Section 157 | Core international shipping profits

(1)A member’s core international shipping profits for a period are the member’s core international shipping revenue for the period less the member’s core international shipping costs for the period.

(2)A member’s core international shipping revenue is all revenue earned by the member in consideration for the member’s performance of core international shipping activities.

(3)A member’s core international shipping costs are the sum of—

(a)all costs incurred by the member that are directly attributable to the member’s performance of core international shipping activities, and

(b)all costs incurred by the member that are indirectly attributable to the member’s performance of core international shipping activities multiplied by the core international shipping factor.

(4)The core international shipping factor is the member’s core international shipping revenue divided by all revenue earned by the member from any source.

(5)An activity is a core international shipping activity if it is of a type referred to in subsection (6).

(6)The types of activity are—

(a)carrying out international shipping, whether alone or in conjunction with another person;

(b)leasing as lessor a ship to be used for international shipping, where—

(i)the ship is leased fully equipped, crewed and supplied, or

(ii)the lessee is a member of the same multinational group and the purpose of the lease is to allow that member to carry out a core international shipping activity;

(c)arranging for another person to carry out international shipping under slot-chartering arrangements;

(d)the sale of a ship used in international shipping, where the ship has been held for use by the member for at least one year.