Global Minimum Tax (GloBE)

The Global Minimum Tax or Global Anti-Base Erosion (GloBE) is an international agreement under the OECD/G20 Inclusive Framework on BEPS ensuring multinational enterprise (MNE) groups with consolidated revenue of at least EUR 750 million pay an effective tax rate of at least 15 percent in every jurisdiction where they operate. When the Effective Tax Rate (ETR) in a jurisdiction falls below 15 percent, a top-up tax applies to close the gap. GloBE works through three core mechanisms: the Income Inclusion Rule (IIR) that charges top-up tax at the parent entity, the Qualified Domestic Minimum Top-up Tax (QDMTT) collected in the subsidiary jurisdiction, and the Undertaxed Payment Rule (UTPR) as a backstop. Indonesia adopts GloBE through MoF Regulation 136/2024 with administrative procedures under PER-6/PJ/2026 effective 4 May 2026.

This article is for education, not tax advice.

Example

PT Gamma is an Indonesian Constituent Entity of Group Delta with EUR 1 billion in consolidated revenue. In 2025, PT Gamma's ETR in Indonesia is 12 percent due to a tax holiday facility. The 3 percent gap to 15 percent is collected as top-up tax via QDMTT, so the revenue stays in Indonesia rather than being diverted to Group Delta's parent jurisdiction.

Source: MoF Regulation 136/2024, PER-6/PJ/2026, OECD GloBE Model Rules