Global Minimum Tax (GMT) filing in Vietnam follows a six-step compliance sequence under Resolution 107/2023/QH15 and Decree 236/2025/ND-CP (effective October 15, 2025). MNE groups with EUR 750 million or more in global consolidated revenue must register, reconcile, and file through the General Department of Taxation (GDT) — with the first deadline arriving just 30 days after fiscal year-end.
For the broader policy context — scope, QDMTT/IIR mechanics, safe harbor logic, and loss treatment — see our GMT implementation overview.
Step 1: Confirm GMT Scope
GMT obligations apply when the ultimate parent entity (UPE) reports consolidated revenues of EUR 750 million or more in at least two of the four preceding fiscal years. Every Vietnamese subsidiary, branch, and permanent establishment then qualifies as a constituent entity (CE) under Resolution 107/2023/QH15.
Previously acquired CIT incentives don’t provide exemption. If those incentives push your effective tax rate below 15%, the QDMTT top-up tax covers the difference.
Step 2: Nominate the Filing CE (Form 01/TB-DVHT)
Groups with multiple Vietnamese entities must designate one CE to handle all GMT filings. Form 01/TB-DVHT is due within 30 days after fiscal year-end via the GDT eTax portal.
If your group misses this window, the GDT defaults to the CE with the largest total asset value — typically the manufacturing entity, which rarely has the accounting depth for international tax reconciliation. Nominate the entity with IFRS-capable finance staff.
Step 3: Register the GMT Tax Code (Form 01-DKTD-DVHT)
The designated CE then registers for a dedicated 10-digit GMT tax code via Form 01-DKTD-DVHT, due within 90 days after fiscal year-end. This code is completely separate from your existing corporate tax ID.
All GMT payments — top-up tax declarations, GloBE Information Returns — route through this code exclusively. Using your standard CIT code for GMT remittances causes fund misallocation and triggers late payment penalties even when the correct amount was paid.
Step 4: Reconcile VAS with IFRS (Form 01/TM)
This is where GMT compliance gets technically demanding. GloBE calculations use the UPE’s accounting standard (typically IFRS), but Vietnamese CEs maintain books under VAS.
Form 01/TM requires your filing entity to document and explain every material difference. Three areas consistently cause issues:
- Depreciation: VAS and IFRS diverge on useful life assumptions and revaluation
- Revenue recognition: IFRS 15 timing differences vs VAS standards
- Inventory valuation: Method differences affect cost of goods sold and GloBE income
This reconciliation isn’t a year-end exercise. It requires concurrent tracking throughout the fiscal year — retrofitting 12 months of accounting differences under deadline pressure is where most errors originate. Companies already managing VAS-IFRS dual reporting have a significant head start.
Step 5: Submit Returns via eTax Portal
All filings go through the GDT eTax portal (thuedientu.gdt.gov.vn). The key deadlines:
| Filing | First Year (FY2024) | Subsequent Years |
|---|---|---|
| QDMTT Returns (01/TKTT-QDMTT + 01/TNDN-QDMTT) | 18 months after FYE | 15 months after FYE |
| IIR Returns + GloBE Information Return | 18 months after FYE | 15 months after FYE |
Top-up tax payment is due concurrently with the return — interest accrues from the filing deadline, not the payment date.
Step 6: Transitional Safe Harbors & Penalties
The Transitional CbCR Safe Harbor (FY2024–2026) can reduce top-up tax to zero if your group passes any one of three tests: simplified ETR (15%/16%/17% by year), routine profits, or de minimis (revenue below EUR 10 million).
What the safe harbor does not cover:
- Late filing: Missing the 30-day/90-day/return deadlines triggers penalties under Decree 125/2020/ND-CP — up to VND 25 million (~USD 1,000)
- Late payment: Underpaid top-up tax accrues 0.03% per day (~11% annually) under Law 38/2019/QH14
The relief covers calculation errors from accounting standard differences. It does not cover missed deadlines or underpayment.
Filing Timeline at a Glance
| Deadline | Action | Form |
|---|---|---|
| FYE + 30 days | Nominate filing CE | 01/TB-DVHT |
| FYE + 90 days | Register GMT tax code | 01-DKTD-DVHT |
| Ongoing | VAS-to-IFRS reconciliation | Internal |
| FYE + 18 months (first year) | Submit QDMTT + IIR returns | 01/TKTT-QDMTT, 01/TM |
| FYE + 15 months (subsequent) | Submit QDMTT + IIR returns | Same |
GMT compliance sits at the intersection of Vietnamese tax administration, international accounting standards, and cross-border transfer pricing documentation. For CE nomination strategy, VAS-to-IFRS reconciliation, and GloBE return preparation, contact our Certified CPAs and tax compliance team — Steven Nguyen and David Nguyen guide eligible MNEs through the filing process under Decree 236/2025/ND-CP.
This guide reflects GMT filing requirements current as of March 2026 under Decree 236/2025/ND-CP and Decision 3563/QĐ-BTC. Implementing guidance from the General Department of Taxation may introduce additional procedures — consult qualified tax advisors for group-specific compliance planning.
