BIR gears up for possible MNE top-up tax rollout

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MANILA, Philippines – The Bureau of Internal Revenue (BIR) is preparing for the rollout of the planned domestic top-up tax for large multinational enterprise groups (MNEs) earning income in the Philippines.

In a statement on Thursday, the BIR said it is preparing for the Department of Finance’s (DOF) Qualified Domestic Minimum Top-Up Tax (QDMTT) proposal through discussions on compliance, reporting, audits, and institutional capacity.

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In September 2025, the DOF first proposed the QDMTT as a tax rule aligned with the OECD’s Global Minimum Tax framework. It ensures MNEs pay a minimum global tax rate of 15 percent on income arising in each country where they operate.