ECONOMIC SUBSTANCE OUTSOURCING
An entity engages in "shipping business" where it conducts any of the following activities involving the operation of a ship anywhere in the world other than in the territorial waters of the jurisdiction where registered:
(a) the business of transporting by sea, passengers or animals, goods or mail for a charge;
(b) the renting or chartering of ships for the purpose described in paragraph (a);
(c) the sale of travel tickets and ancillary ticket related services connected with the operation of a ship;
(d) the use, maintenance or rental of containers, including trailers and other vehicles or equipment for the transport of containers, used for the transport of anything by sea; or
(e) the functioning as a private seafarer recruitment and placement service,
but does not include a holding company business or the owning, operating or chartering of a pleasure yacht.