Global Minimum Tax Implementation in Vietnam: Decree 236
In 2023, Vietnam issued Resolution No. 107/2023/QH15 (“Resolution 107”), introducing an additional corporate income tax (CIT) aligned with global rules on preventing base erosion and profit shifting (GloBE), using the Global Minimum Tax (GMT) as the primary mechanism.
To implement Resolution 107, the government released Decree 236, which sets out Vietnam’s GMT framework under the OECD’s Pillar Two initiative. The framework centers on two key rules: the Income Inclusion Rule (IIR) and the Qualified Domestic Minimum Top-Up Tax (QDMTT).
While the final decree maintains the structure of the earlier draft, it introduces clarifications to ensure alignment with OECD guidance and greater consistency in interpretation. Although Decree 236 takes effect on October 15, 2025, its provisions apply retroactively from the fiscal year 2024, requiring businesses to prepare early and strengthen compliance systems.
OECD: Vietnam’s legislation achieves transitional qualified status
As of August 18, 2025, the OECD’s Central Record of Legislation with Transitional Qualified Status lists Vietnam among the jurisdictions whose IIR and QDMTT frameworks are recognized as meeting the necessary standards. Vietnam’s QDMTT framework also qualifies for the safe harbor mechanism.
Notable provisions on QDMTT and IIR under Decree 236
General provisions
| QDMTT | IIR |
Effective date |
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Subject of application |
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Applicable tax rate |
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Exclusion from QDMTT for MNEs in the initial phase
The additional tax under the QDMTT in Vietnam is set to zero during the initial phase of implementing international investment activities of an MNE group, provided that:
- The MNE group has CEs in no more than six jurisdictions; and
- The total book value of tangible assets of all CEs in all countries, excluding the reference jurisdiction, does not exceed USD 50 million.
This exemption will be valid for five years from the first fiscal year in which the MNE group falls within the scope of the GloBE rules. The jurisdiction where the MNE group holds the highest total value of tangible assets during the first fiscal year in which the group initially falls within the scope of the GloBE rules.
QDMTT safe harbor
An MNE group’s top-up tax under IIR for a jurisdiction is considered zero if the QDMTT in that jurisdiction meets the conditions for the QDMTT safe harbor, as outlined by the Inclusive Framework on BEPS. Otherwise, the top-up tax amount cannot be exempt if the MNE group is not subject to QDMTT in this jurisdiction, or if the tax authority in this jurisdiction is unable to collect QDMTT for the related CE.
IIR top-up tax ordering rule
The IIR top-up tax is applied in order of priority along the parent chain, beginning with the UPEs, followed by the partially-owned parent entities (POPEs), and then the intermediate parent entity (IPEs).
How Decree 236 alters Vietnam’s financial accounting standards
| QDMTT | IIR |
Accounting standard |
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Exchange rate |
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Condition for determining QDMTT amount as zero |
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Tax registration and filing requirements
Notification on the Appointment of the Filing CE and In-Scope CEs
MNE groups must notify the appointment of the Filing CE and provide the list of in-scope CEs using Form No. 01/TB-DVHT. This notification must be submitted within 30 days after the end of the fiscal year, either directly, by post, or through the electronic transaction portal.
Where the tax authority appoints a Filing CE through Form No. 02/TB-DVHT, the appointed entity is required to submit Form No. 01/TB-DVHT to the tax authority within 10 days from the date of appointment.
Tax registration
The appointed Filing CE must complete tax registration using Form No. 01-DKTD-DVHT, in order to obtain a 10-digit tax code number for tax declaration and payment purposes. The filing deadline is 90 days after the end of the fiscal year.
For MNE groups with a 2024 fiscal year ending on or before 30 June 2025, the deadline is 90 days from the effective date of the Decree, but no later than the statutory deadline for tax filing. Submissions must be made via the electronic transaction portal.
Tax filing and payment
For QDMTT, the Filing CE must complete tax filing and payment within 12 months after the end of the fiscal year. Both submission and payment are made through the electronic transaction portal.
For the IIR, the deadline is extended to 15 months after the end of the fiscal year, with a longer timeline of 18 months for the first year of implementation. Submissions and payments are also processed via the electronic transaction portal.
Detailed procedures for each case are outlined as follows:
| QDMTT | IIR |
Information Return |
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Supplementary CIT return |
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Explanation of variations caused by differences between financial accounting standards |
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GloBE Information Return |
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Reporting package of each CE used for preparing consolidated FS of the UPE |
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Consolidated FS of the UPE | Not applicable | Consolidated FS of the UPE; and Original or copy version |
Takeaways for multinational corporations
With Vietnam now recognized by the OECD as meeting necessary standards, Decree 236 marks a crucial step in improving the country’s tax environment and tackling global tax base erosion. However, there are several key points businesses should be aware of, including:
- The deadline for submitting the Notification on the Appointment of the Filing CE and the List of in-scope CEs has already passed, and immediate action is recommended to ensure compliance; and
- For tax registration, the appointed Filing CE must complete registration within the specified timeframe. Notably, MNE groups with a 2024 financial year ending on or before June 30, 2025, can benefit from an extended deadline of 90 days from the effective date of the Decree (October 15, 2025), but no later than the statutory deadline for tax filing.
(US$1 = EUR 0.86)
