TRANSFER PRICING

Pillar 2 - Global Minimum Tax

Navigating the Global Minimum Tax landscape

Support MNEs with GMT compliance and impact assessment under OECD rules


The year 2025 marks a new dawn in the Malaysian tax landscape with the implementation of Global Minimum Tax ("GMT") regime for large multinationals, aligned with international tax development towards a fairer corporate taxation system. Multinationals with annual revenues of at least EUR 750 million, in at least 2 of the 4 consecutive financial years immediately preceding the tested financial year, shall be subject to either the Multinational Top-up Tax (MTT) or Domestic Top-up Tax (DTT), as stipulated in Part XI of the Malaysian Income Tax Act 1967. The GMT legislation will take effect from 1 January 2025.

Constituent Entities (CE) of a MNE group shall prepare and submit to the Inland Revenue Board of Malaysia a GloBE Information Return and a Top-up Tax Return for each Financial Year electronically not later than 15 months from the last day of the Reporting Financial Year.

How we can help

Our team supports you in response to the OECD Pillar 2 GMT requirements, managing the impact on group effective tax rates and reporting obligations, including:

  • GMT advisory
  • GMT compliance

Your smarter choice in managing transfer pricing

We have deep transfer pricing knowledge and experience spanning decades and across industries. We use a collaborative and custom approach to develop solutions tailored for your unique situation.

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Our latest thinking and news

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business meeting
Strong management builds the foundation for governance and risk oversight
Strong leadership and ethical governance drive resilience and trust in Malaysia’s evolving corporate landscape.
Tax consultant assisting client with financial reports and tax documents at office desk
Service Tax Expansion 2025 Updates (October 2025)
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We are here to help

Working together we can help you successfully adapt and overcome the challenges you may face, both today and in the future.
Foo Meng Huei
Meng Huei Foo
Head of TaxKuala Lumpur
Song Sylvia
Sylvia Song
Partner, Transfer PricingKuala Lumpur
Wong Chun Kit
Chun Kit Wong
Partner, Transfer PricingKuala Lumpur