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Global Minimum Tax Services

The introduction of the Global Anti-Base Erosion (GloBE) rules as part of Pillar Two marks a new era in international taxation, aiming to ensure that large Multinational Enterprises (MNEs) pay a minimum effective tax rate of 15% in every jurisdiction where they operate.


The complexity of Global Minimum Tax calculations and its significant impact on the tax structure of MNEs demand deep understanding and strategic preparation. MUC Consulting offers comprehensive solutions designed to ensure full compliance while identifying tax efficiency opportunities for your MNE Group.

Global Minimum Tax Insights

Building Competence, MUC Consulting Holds FGD on Global Minimum Tax

Building Competence, MUC Consulting Holds FGD on Global Minimum Tax
MUC Consulting held a Focus Group Discussion (FGD) on the Global Minimum Tax (GMT) Regulation PMK 136/2024 to enhance tax consultants’ understanding of international tax regulations.

When the Global Minimum Tax Impacts Commercial Financial Statements
The 15% Global Minimum Tax (GMT) impacts commercial financial statements. Amendments to PSAK 212 and Ministry of Finance Regulation (PMK) Number 136/2025 require companies to disclose coverage and potential top-up tax exposure.
Read more

Services

Comprehensive Global Minimum Tax Training

In-depth and structured training programs for your internal team, designed to build a strong understanding of the GloBE rules, its mechanisms (IIR, UTPR, DMTT), and implications for your business.

Global Minimum Tax Risk Analysis and Provisioning

Conducting a deep analysis of your MNE structure to identify potential risks and additional tax liabilities (top-up tax). This service includes preparing the Global Minimum Tax Provision for financial reporting, aligned with applicable accounting standards.

Global Minimum Tax Safe Harbour Provision Analysis Report

Evaluating your MNE Group’s eligibility to utilize Safe Harbour provisions (such as the Transitional CbCR Safe Harbour or Permanent Safe Harbour) to simplify reporting and compliance obligations.

Effective Tax Rate (ETR) Calculation

Detailed calculation of the Jurisdictional ETR in accordance with the GloBE rules, serving as the basis for determining potential Top-up Tax.

Global Minimum Tax Reporting & Compliance

Comprehensive assistance in the preparation of all compliance reports related to the Global Minimum Tax, including the GloBE Information Return (GIR), Notification, and the Annual Income Tax Return for GloBE/UTPR/DMTT.

Impact Assessment of Global Minimum Tax Implementation

A thorough assessment of the financial, operational, and data impacts of Global Minimum Tax implementation on your MNE Group, enabling proactive and informed decision-making.

Experts

Director is Professional in Charge of Global Minimum Tax
Zulhanief Matsani
Director
Head of Pillar Two<br>Tax Advisory Services is Professional in Charge of Global Minimum Tax
Nendi Bahtiar
Head of Pillar Two
Tax Advisory Services
Frequently Asked Questions

Related Video with GMT

MUC Exclusive Training Global Minimum Tax

MUC Exclusive Training Global Minimum Tax

MUC Consulting kembali sukses menyelenggarakan Exclusive Training perpajakan, pada Kamis (21/8) di MUC Building. Kali ini acara tersebut membahas hal-hal teknis seputar implementasi pajak minimum global oleh Transfer Pricing Manager dan sekaligus sebagai Head of Pillar 2 Tax Advisory Services MUC Consulting, Nendi bahtiar. Berikut tanggapan dari sejumlah peserta yang hadir.

PAJAK MINIMUM GLOBAL

PAJAK MINIMUM GLOBAL

Pajak minimum global bukan lagi wacana, tapi sudah jadi aturan resmi lewat PMK-136/2024. Aturan ini lahir dari kesepakatan lebih dari 140 negara di bawah OECD/G20. Tujuannya? Mencegah perusahaan multinasional memindahkan keuntungan ke negara pajak rendah untuk bayar lebih sedikit pajak. Sekarang, setiap perusahaan multinasional dengan omzet jumbo (di atas EUR 750 juta per tahun), wajib membayar pajak efektif minimal 15%, di mana pun mereka berada. Kalau pajaknya di bawah itu? Negara tertentu bisa kenakan Top-Up Tax lewat mekanisme DMTT, IIR, dan UTPR. Ini adalah langkah besar menuju sistem perpajakan global yang lebih adil — dan Indonesia punya peluang untuk ikut di barisan depan.

STRATEGI MENGHADAPI PAJAK MINIMUM GLOBAL

STRATEGI MENGHADAPI PAJAK MINIMUM GLOBAL

Cuplikan Webinar MUC BIJAK tentang Strategi Menghadapi Pajak Minimum Global, yang berlangsung belum lama ini.

Frequently Asked Questions

What is Global Minimum Tax?

The global minimum tax is the implementation of Minister of Finance Regulation (MoFR) 136 of 2024, which comes into effect in Indonesia for FY 2025. Its main objective is to ensure that multinational enterprises (MNEs) pay a fair minimum tax in every country where they operate, in order to reduce tax avoidance practices and low tax rate competition among countries, thus a globally applicable minimum tax rate of 15% has been set.

Who is in scope of the Global Minimum Tax rules?

Multinational enterprise groups with consolidated annual revenue of at least €750 million in 2 (two) out of the 4 (four) fiscal years preceding the GloBE assessment year.

What is a Multinational Enterprise (MNE)?

A group of entities that has at least one entity or a permanent establishment (PE) outside the country where the ultimate parent entity is located.

Are there entities excluded from the Global Minimum Tax?

Yes, the following entities are excluded from the application of the Global Minimum Tax:

  • Government entities
  • International organisations
  • Non-profit organisations
  • Pension funds
  • Investment funds that are a UPE (ultimate parent entity)
  • Real estate investment vehicles that are a UPE

Our company already pays 22% corporate income tax, does that mean we don’t need to implement the Global Minimum Tax?

Not necessarily, the global minimum tax rules differ from the applicable corporate income tax rate. Taxpayers need to calculate the Effective Tax Rate (ETR) to determine whether the tax paid by companies in a country or jurisdiction is above or below 15%.

What if the ETR is below 15%?

If the ETR is below 15%, a Top-up Tax will be imposed equal to the difference between 15% and the ETR. 

What is the Global Minimum Tax Charging Mechanism? 

The Global Minimum Tax Charging Mechanism is a mechanism that regulates how and where Top-up Tax payments are made. There are 3 Global Minimum Tax Charging Mechanism schemes, namely: Income Inclusion Rule (IIR), Undertaxed Payment Rule (UTPR), or Qualified Domestic Minimum Top-Up Tax (QDMTT).

What are IIR, UTPR, and QDMTT?

  • Income Inclusion Rule (IIR): Additional tax imposed on the UPE in respect of the low taxed income of a constituent entity.
  • Undertaxed Payment Rule (UTPR): Additional tax imposed on the jurisdiction where the UPE is located on payments received from low taxed income of a constituent entity.
  • Qualified Domestic Minimum Top-up Tax (QDMTT): An additional domestic tax that may be imposed by a jurisdiction to cover the shortfall in the global minimum tax.

When is the Top‑up Tax due?

The due date for Top-up Tax payments is 1 (one) year. For example, for companies with an accounting period from Jan-Dec 2025, the payment due date is in December 2026.

What are the administrative obligations related to the Global Minimum Tax?

  • GloBE Information Return (GIR), reported by the UPE Notification, reported by the constituent entity
  • Annual GloBE Income Tax Return, reported by the UPE located in Indonesia
  • Annual DMTT Income Tax Return, reported by the constituent entity
  • Annual UTPR Income Tax Return (SPT), reported by the constituent entity.

When must these administrative obligations be reported?

  • First Year of Imposition
    GIR, Notification, and Annual Tax Return (GloBE, DMTT, UTPR) must be submitted no later than 18 months after the end of the first fiscal year.

  • Second and Subsequent Years
    GIR and notifications must be submitted 15 months after the end of the fiscal year.
    Annual Tax Returns for GloBE, DMTT, and UTPR must be submitted 16 months after the end of the fiscal year.

Are there any administrative reliefs related to the implementation of the Global Minimum Tax?

Yes. There are safe harbor rules for companies that meet certain criteria to ease their administrative obligations. 
Companies need to pay attention to the safe harbor rules explained further in MoFR 136 of 2024, including: 
1. De-minimis rules; 
2. Routine profit rules; dan 
3. Simplified ETR 

What should taxpayers prepare?

Companies need to study and understand the provisions in PMK 136 of 2024 to ensure compliance. 
Coordinating with entities within the group and tax consultants to ensure proper implementation. 
Preparing an internal team and collecting the necessary data for tax reporting and calculation. 
Conducting simulations to ensure effective tax rates above 15% and identify potential Top-up Tax. 
Utilizing safe harbor provisions to reduce compliance burdens, if eligible. 

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