In a 22 May 2026 update, the Inland Revenue Board published Frequently Asked Questions on the implementation of the Global Minimum Tax (GMT) in Malaysia Version 8.0, which addresses critical implementation questions affecting multinational enterprises.
The Inland Revenue Board of Malaysia (IRBM) has released updated guidance on the Pillar Two global minimum tax regime, clarifying filing obligations for local businesses. In a 22 May 2026 update, the Inland Revenue Board published Frequently Asked Questions on the implementation of the Global Minimum Tax (GMT) in Malaysia Version 8.0, which addresses critical implementation questions affecting multinational enterprises.
Malaysian-based constituent entities are exempt from submitting GMT-related documentation—including the Global Anti-Base Erosion Information Return, notifications, and top-up tax filings—for financial years commencing before 1 January 2025. This provides immediate relief for firms still preparing for compliance.
However, Malaysian entities operating in jurisdictions that have already activated the GMT from 2024 onwards remain bound by those countries’ filing and compliance obligations. The exemption does not shield businesses from enforcement in other territories that have adopted the OECD standard earlier.
The updated GMT FAQs include the following new questions and answers:
Chapter 13 of Part XI of the ITA – Returns
22. Q: Whether the Malaysian constituent entities are required to submit any GMT-related filings for the financial year ended 31 December 2024, including:
- GIR Notification
- Information Return; and/or
- the Top-up Tax Return
A: Malaysian CEs are not required to submit any GMT-related filings for the financial year beginning prior to 1 January 2025 in Malaysia. However, if the CEs have operations in jurisdictions that apply GMT from 2024, they remain subject to the GMT filing rules in those jurisdictions.
Domestic Top-up Tax
28. Q: If the effective tax rate (ETR) for all Malaysian Constituent Entities exceeds 15%, do we still need to file the Domestic Top-up Tax return?
A: Yes. Even if there is no Top-up Tax liability, the Domestic Top-up Tax Return must still be filed for each year in which the Constituent Entity is in scope of GMT in Malaysia.
GMT Status Reporting in Tax Return
Q. 1. Form C – Item H9a
We note that various tax return forms (e.g., Form C – item H9a) now include a field on GMT status, asking whether the taxpayer is subject to Domestic Top-up Tax or Multinational Top-up Tax under Part XI of the Income Tax Act 1967. Should the taxpayer select “YES” if they are within the scope of GMT but will not have any liability for Domestic Top-up Tax or Multinational Top-up Tax for the financial year, or should they instead select “NO” in such circumstances?
A: Select “YES” when the taxpayer is in scope of GMT when its MNE Group has consolidated revenues of at least EUR 750 million in not less than two of the four preceding financial years, even if its Domestic Top-up Tax or Multinational Top-up Tax is expected to be “Nil” for that financial year.
Q. 2. Form C – Item H9a and H9b
In the Tax Return Form C for the Year of Assessment 2025, there is a notification field for GMT status. If the fields H9a and H9b are not accessible via e-filing due to the company’s accounting period commencing in 2024 but still forming part of the UPE’s consolidated financial statements for the financial year beginning 1st January 2025, please advise the alternative steps for the affected Company to fulfil its Pillar 2 notification requirements under the Form C.
A: The system logic has been designed to block cases where the company’s accounting period begins in 2024. Accordingly, if a taxpayer is subject to GMT due to the UPE’s consolidated accounts commencing on 1 January 2025, the taxpayer must notify the Inland Revenue Board of [Malaysia] via email at tf2p@hasil.gov.my, stating that the company is subject to Part XI of the Income Tax Act 1967, and to provide the name and jurisdiction of the Ultimate Parent Entity.
