Brussels, 14 March 2022
On the 14th of March, the OECD published the Commentary on the Global Anti-Base Erosion (GloBE) Rules for the BEPS Pillar 2. The paper provides technical guidance on the operation and intended outcomes under the Pillar 2 rules.
The Commentary states that inland transportation could be considered as ancillary to an international shipping income by the OECD Model Tax Convention, but it is not covered by the exclusion of international shipping income and its related activities. Inland transportation should therefore be subject to the global minimum corporate tax. The Commentary recognizes that including inland transportation in the scope of the corporate tax “mitigates the risk of competitive distortions between shipping companies that have vertically integrated such services and independent freight forwarding and land-based logistics service providers.”