
David Lai
As gazetted in the Finance (No.2) Act 2023, Malaysia is set to implement the Global Minimum Tax ("GMT") from 1 January 2025. The Malaysian GMT rules are largely adopted from the OECD Global Anti-Base Erosion ("GloBE") Model Rules to align with the global implementation. The GMT rule is aimed at ensuring a top-up tax is imposed on jurisdictions where the Multinational Enterprise ("MNE") Group operates, where the effective tax rate ("ETR") is below 15%.
The two types of top-up tax being imposed in Malaysia include Domestic Top-Up Tax ("DTT") and Multinational Top-Up Tax ("MTT"). The rule will apply to members of a MNE Group with an annual consolidated revenue of EUR 750 million or more in at least two of the four immediately preceding financial years.
Assessment & Planning
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