The Global Minimum Tax Agreement is essential for multinational enterprise groups operating in Malta with consolidated annual revenue exceeding €750 million. This document becomes necessary when implementing the OECD Pillar Two framework and ensuring compliance with EU Directive 2022/2523 within Malta's jurisdiction. It provides comprehensive guidance on calculating effective tax rates, applying top-up taxes, and meeting reporting requirements under both international and domestic frameworks. The agreement is particularly relevant for groups with complex international structures and those seeking to ensure compliance with Malta's implementation of the global minimum tax regime. It includes detailed provisions for both the Income Inclusion Rule and Undertaxed Payments Rule, along with specific considerations for Malta's domestic minimum top-up tax mechanisms.
Global Minimum Tax Agreement for Malta
Create a bespoke document in minutes, or upload and review your own.
Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.
Get your first 2 documents free
Your data doesn't train Genie's AI
You keep IP ownership of your information
Key Requirements PROMPT example:
Global Minimum Tax Agreement
"I need a Global Minimum Tax Agreement for our Malta-based multinational technology group with annual revenue of €2.3 billion, with specific provisions for our R&D operations and intellectual property holdings across EU jurisdictions."
Your data doesn't train Genie's AI
You keep IP ownership of your information
Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.
OR
Let Genie AI's market-leading legal AI identify missing terms, unusual language, compliance issues and more - in just seconds.
Upload your Doc
1. Parties: Identification of the parties entering into the agreement, including tax authorities and relevant corporate entities
2. Background: Context of the agreement, including reference to OECD Pillar Two rules and applicable EU directives
3. Definitions: Key terms including Ultimate Parent Entity, Constituent Entity, GloBE Income, Qualified Domestic Minimum Top-up Tax (QDMTT), etc.
4. Scope and Application: Details of which entities fall under the agreement (revenue thresholds, group structure requirements)
5. Calculation of Effective Tax Rate: Methodology for calculating the effective tax rate and top-up tax
6. Income Inclusion Rule: Implementation and application of the primary rule for collecting top-up tax
7. Undertaxed Payments Rule: Secondary mechanism for collecting top-up tax when IIR doesn't apply
8. Filing Requirements: Requirements for documentation, returns, and notifications
9. Payment and Collection: Procedures for payment of top-up tax and collection mechanisms
10. Compliance and Enforcement: Measures ensuring compliance and consequences of non-compliance
11. Dispute Resolution: Procedures for resolving disputes regarding tax calculations or interpretations
12. Term and Termination: Duration of the agreement and conditions for termination
1. Safe Harbors: Include when simplified compliance mechanisms are agreed upon for qualifying entities
2. Transitional Provisions: Include when specific arrangements are needed for the initial implementation period
3. Industry-Specific Provisions: Include when dealing with regulated industries (e.g., financial services, insurance) requiring special treatment
4. Group Relief Provisions: Include when addressing interaction with existing group relief mechanisms
5. Excluded Entities: Include when certain entities qualify for exclusion under OECD rules
6. De Minimis Exclusion: Include when implementing simplified requirements for jurisdictions with minimal revenues
1. Calculation Methodology: Detailed steps and formulas for calculating effective tax rate and top-up tax
2. Reporting Template: Standardized format for required reports and returns
3. Group Structure Chart: Diagram showing relevant group entities and their relationships
4. Timeline for Implementation: Key dates and deadlines for various compliance requirements
5. Excluded Territories: List of territories where special rules or exclusions apply
6. Documentation Requirements: Detailed list of required supporting documentation
Authors
Relevant legal definitions
Acceptable Accounting Standard
Agreed-Upon Procedures
Blended CFC Tax
Constituent Entity
Controlling Interests
Covered Taxes
Deemed Distribution Tax
Disqualified Refundable Imputation Tax
Effective Tax Rate
Excluded Entity
Filing Constituent Entity
GloBE Income
GloBE Rules
Group Revenue Test
Income Inclusion Rule (IIR)
International Shipping Income
Investment Entity
Joint Venture
Large-Scale Domestic Group
Low-Tax Jurisdiction
MNE Group
Minority-Owned Constituent Entity
Net GloBE Income
Non-Qualified Refundable Tax Credit
Ownership Interest
Parent Entity
Permanent Establishment
Pillar Two GloBE Rules
Qualified Domestic Minimum Top-up Tax (QDMTT)
Qualified Income Inclusion Rule
Qualified Refundable Tax Credit
Qualified Undertaxed Payments Rule
Qualifying Competent Authority Agreement
Reporting Fiscal Year
Strategic Activities Exception
Substance-based Income Exclusion
Tax Transparent Entity
Top-up Tax
Ultimate Parent Entity (UPE)
Undertaxed Payments Rule (UTPR)
UTPR Jurisdiction
Agreed-Upon Procedures
Blended CFC Tax
Constituent Entity
Controlling Interests
Covered Taxes
Deemed Distribution Tax
Disqualified Refundable Imputation Tax
Effective Tax Rate
Excluded Entity
Filing Constituent Entity
GloBE Income
GloBE Rules
Group Revenue Test
Income Inclusion Rule (IIR)
International Shipping Income
Investment Entity
Joint Venture
Large-Scale Domestic Group
Low-Tax Jurisdiction
MNE Group
Minority-Owned Constituent Entity
Net GloBE Income
Non-Qualified Refundable Tax Credit
Ownership Interest
Parent Entity
Permanent Establishment
Pillar Two GloBE Rules
Qualified Domestic Minimum Top-up Tax (QDMTT)
Qualified Income Inclusion Rule
Qualified Refundable Tax Credit
Qualified Undertaxed Payments Rule
Qualifying Competent Authority Agreement
Reporting Fiscal Year
Strategic Activities Exception
Substance-based Income Exclusion
Tax Transparent Entity
Top-up Tax
Ultimate Parent Entity (UPE)
Undertaxed Payments Rule (UTPR)
UTPR Jurisdiction
Clauses
Scope and Application
Calculation Methodology
Income Inclusion Rule
Undertaxed Payments Rule
Qualified Domestic Minimum Top-up Tax
Filing Obligations
Notification Requirements
Payment and Collection
Reporting Standards
Confidentiality
Record Keeping
Information Exchange
Compliance and Enforcement
Anti-Avoidance
Dispute Resolution
Penalties and Interest
Transitional Provisions
Amendments
Governing Law
Force Majeure
Severability
Entire Agreement
Notices
Term and Termination
Calculation Methodology
Income Inclusion Rule
Undertaxed Payments Rule
Qualified Domestic Minimum Top-up Tax
Filing Obligations
Notification Requirements
Payment and Collection
Reporting Standards
Confidentiality
Record Keeping
Information Exchange
Compliance and Enforcement
Anti-Avoidance
Dispute Resolution
Penalties and Interest
Transitional Provisions
Amendments
Governing Law
Force Majeure
Severability
Entire Agreement
Notices
Term and Termination
Relevant Industries
Financial Services
Manufacturing
Technology
Telecommunications
Retail
Energy
Pharmaceutical
Professional Services
Insurance
Real Estate
Transportation and Logistics
Media and Entertainment
Relevant Teams
Finance
Tax
Legal
Compliance
Treasury
International Operations
Corporate Governance
Financial Reporting
Risk Management
Regulatory Affairs
Relevant Roles
Chief Financial Officer
Tax Director
Head of International Tax
Global Tax Manager
Tax Compliance Manager
Corporate Controller
Finance Director
Legal Counsel
Compliance Officer
Group Financial Controller
International Tax Advisor
Transfer Pricing Manager
Tax Policy Director
Treasury Manager
Financial Reporting Manager
Find the exact document you need
Global Minimum Tax Agreement
Malta-compliant Global Minimum Tax Agreement implementing OECD Pillar Two rules and EU requirements for qualifying multinational enterprises.
find out more
Agreement For Avoidance Of Double Taxation
A bilateral treaty under Maltese law establishing tax treatment frameworks between Malta and another state to prevent double taxation and tax evasion.
find out more
Double Tax Avoidance Agreement
A bilateral treaty under Maltese law preventing double taxation between Malta and another state, establishing comprehensive framework for cross-border tax treatment.
find out more
Instalment Agreement
A Maltese law-governed agreement establishing terms for structured payments in instalments, detailing payment schedule, interest, and default provisions.
find out more
Tax Exchange Information Agreement
A Maltese law-governed agreement establishing tax information exchange procedures between Malta and another jurisdiction, ensuring compliance with EU and international standards.
find out more
Tax Payment Agreement
A Maltese law-governed agreement between a taxpayer and the Commissioner for Revenue establishing structured payment terms for outstanding tax liabilities.
find out more
Advance Price Agreement
A Maltese law-governed agreement between taxpayer and tax authorities establishing approved transfer pricing methodologies for related-party transactions.
find out more
Tax Sharing Agreement
A Maltese law-governed agreement establishing tax liability sharing arrangements between group companies, compliant with local and EU tax regulations.
find out more
Genie’s Security Promise
Genie is the safest place to draft. Here’s how we prioritise your privacy and security.
Your documents are private:
We do not train on your data; Genie’s AI improves independently
All data stored on Genie is private to your organisation
Your documents are protected:
Your documents are protected by ultra-secure 256-bit encryption
We are ISO27001 certified, so your data is secure
Organizational security:
You retain IP ownership of your documents and their information
You have full control over your data and who gets to see it
.png)
.png)