What is QDMTT?

Qualified Domestic Minimum Top-up Tax (QDMTT) refers to a minimum tax that is included in the domestic law of a jurisdiction and determines the Excess Profits of the Constituent Entities located in the jurisdiction (Domestic Excess Profits) in a manner that is equivalent to the GloBE Rules. Malaysia is in the midst of ensuring our Domestic Top-up Tax (DTT) legislation meets the definition of QDMTT.

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