What is an MNE group?

An MNE group means any group that is consolidated for financial accounting purposes and the group includes at least one entity or Permanent Establishment (PE) that is not located in the same jurisdiction of the Ultimate Parent Entity (UPE).

A - MAIN REFERENCE MATERIALS

• Model GloBE Rules (Published 20/12/2021)
• Commentary to the GloBE Rules :
• First Edition (Published 14/03/2022)
• Consolidated Commentary (2023) (Published 25/04/2024)
• Consolidated Commentary to Model GloBE Rules (Published 09/05/2025)
• Agreed Administrative Guidance (AAG):
• Safe Harbours and Penalty Relief (Published 20/12/2022)
• AAG published on 02/02/2023
• AAG published on 17/07/2023
• AAG published on 18/12/2023
• AAG published on 17/06/2024
• AAG published on 15/01/2025 (Article 8)
• AAG published on 15/01/2025 (Article 9)
• AAG published on 05/01/2026 (Side-by-Side Package)^New!
• Guidance on the GloBE Information Return (GIR):
• Guidance published on 17/07/2023
• Guidance published on 15/01/2025 
• GIR (Pillar Two) XML Schema

B - SUPPLEMENTARY REFERENCE MATERIALS

• Summary : Pillar Two Model Rules in A Nutshell
• Pillar Two Model Rules Fact Sheets
• Minimum Tax Implementation Handbook (Published 11/10/2023)
• Illustrative Examples-Updated (Published 02/05/2025)

FOR RELATED GMT ISSUES, PLEASE CONTACT US :

tf2p@hasil.gov.my