The OECD does not directly tax its members but sets international standards that countries adopt into domestic law. Its Pillar Two Global Anti-Base Erosion rules, effective in 2026, impose a 15 percent minimum tax on multinationals with revenues above EUR750 million, reported AI's Copilot.

Shipping companies benefit from a carve-out under Article 3.3 for Qualified International Shipping Income and Qualified Ancillary International Shipping Income. This exemption recognizes the global nature of maritime operations but comes with strict conditions.

To qualify, firms must prove that strategic management decisions, such as capital expenditure, ship pooling, and contract awards, are genuinely made in the jurisdiction where the entity is based. Ancillary income exclusions are tightly limited, requiring segregation of slot charter revenues from inland transport earnings.

Despite the carve-out, shipping multinationals must file comprehensive GloBE Information Returns. Compliance steps include demonstrating local management presence, tracking ancillary income to ensure it remains within thresholds, and adapting to new simplified effective tax rate safe harbors introduced in 2026.

Industry experts warn that without proactive planning, companies risk top-up taxes on non-qualifying bareboat charters and inland operations. Logistics executives are urged to update contracts, strengthen reporting systems, and ensure operational protocols reflect the OECD framework.