What is Malaysia’s position on GloBE Rules?

Malaysia announced its commitment to implementing the Global Minimum Tax (GMT) during the Budget 2024 speech, targeting MNE Groups with consolidated revenues of EUR 750 million or more in at least two of the four consecutive Financial Years immediately preceding the tested Financial Year.

With the enactment of the Finance (No. 2) Bill 2023 on 29 December 2023, the GloBE Rules have been incorporated into Malaysian tax law. Multinational Top-up Tax (MTT) and the Domestic Top-up Tax (DTT) are effective from the financial year beginning on or after 1 January 2025.

This adoption reflects Malaysia's commitment to curbing tax base erosion and profit shifting while maintaining its competitiveness in the global market. By aligning with international tax standards, Malaysia supports fair taxation and at the same time safeguards its tax revenue base.

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