1 June 2026 – The Global Anti-Base Erosion (GloBE) Model Rule—Pillar Two establishes a structured framework for calculating effective tax rates (ETRs) and administering top-up taxes in jurisdictions where the ETR falls below the 15% minimum threshold.
A Multi-National Enterprise (MNE) must submit the Global Minimum Tax Return (GMT01), together with the Global Minimum Tax Declaration form (GMT02) and the tax calculation for the relevant fiscal year of liability.
The Global Minimum Tax (GMT) Returns submission and payment periods are as follows:
- 15 months after the end of the Fiscal Year, or
- 18 months after the end of the first Fiscal Year commencing on or after 1 January 2024 but before 1 January 2025:
- Where the MNE Group is liable to the Top-up Tax and is not required to submit a GMT Return for a previous Fiscal Year in another jurisdiction, ignoring Fiscal Years that precede the Fiscal Year mentioned above.
GMT payment may be made by a Multi-National Enterprise (MNE) or Domestic Constituent Entity (DCE) through the eFiling channel.
A new guide to submit GMT Returns has been developed and the Payment Rules guide has been updated.
