Global Minimum Tax (GMT) filing in Vietnam operates under a structured six-step procedural framework established by National Assembly Resolution 107/2023/QH15 and Decree 236/2025/ND-CP (promulgated on August 29, 2025, taking legal effect from October 15, 2025). Every multinational enterprise (MNE) group reporting consolidated global revenues of EUR 750 million or more in at least two of the four preceding fiscal years must comply with mandatory registration milestones, accounting reconciliation disclosures, and electronic top-up tax returns through the tax authority’s electronic transaction portal.
The earliest deadline, the nomination notice, arrives 30 days after the close of the group fiscal year. The filing sits within CIT compliance for FDI companies. For policy background on the Qualified Domestic Minimum Top-up Tax (QDMTT) and the Income Inclusion Rule (IIR), see the Global Minimum Tax implementation guide. This guide covers the procedures, forms, accounting reconciliation and penalty rules for foreign direct investment (FDI) groups.
Step 1: Confirm GMT Scope and Model Incentive Interactions
Filing obligations apply to groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding fiscal years; every subsidiary, branch and permanent establishment in Vietnam is then a Constituent Entity (CE). Existing corporate income tax incentives do not exempt a group: where they push the Vietnamese effective tax rate below 15%, the top-up tax is payable to the Vietnamese budget. Scope, the effective tax rate test and the safe harbors are explained in the implementation guide.
Step 2: Nominate the Filing Constituent Entity via Form 01/TB-ĐVHT
A group with a single constituent entity in Vietnam files through that entity and needs no designation, but it still sends Form 01/TB-ĐVHT, with the list of its constituent entities, within 30 days of fiscal year-end. When an MNE group maintains multiple constituent entities in Vietnam, the group is not required to submit duplicate administrative filings. Instead, it is entitled to nominate a single designated CE to manage all registrations, disclosures, and tax payments on behalf of all local affiliates.
The nomination is formalized through Form 01/TB-ĐVHT (Notification of Designated Constituent Entity for GMT Administration):
- Deadline: Within 30 calendar days following the close of the group fiscal year (FYE). For groups operating on a standard calendar year ending December 31, the nomination must be submitted no later than January 30 of the following year.
- Submission Channel: In person, by post or electronically through the electronic transaction portal, addressed to the tax authority assigned to manage top-up tax under the global minimum tax rules.
Consequences of a missed nomination deadline
If the 30-day window expires without formal nomination, the tax authority designates the filing entity within the following 30 days by notice on Form 02/TB-ĐVHT. For QDMTT groups, it picks the Vietnamese constituent entity with the largest total assets on the latest annual financial statements, and that entity must submit Form 01/TB-ĐVHT within 10 days of the notice. Groups should therefore nominate proactively and choose an entity staffed with IFRS expertise.
Step 3: Register a Dedicated GMT Tax Code via Form 01-ĐKTĐ-ĐVHT
Following CE nomination, the designated entity must register with tax authorities to obtain a separate 10-digit tax identification number exclusively dedicated to GMT compliance.
This registration is processed through Form 01-ĐKTĐ-ĐVHT:
- Deadline: No later than 90 days after the close of the reporting fiscal year (Article 15.6). For a FY2024 ending on or before June 30, 2025, the deadline is 90 days from the decree’s effective date (October 15, 2025), but not later than the filing and payment deadline.
- Tax Identification Structure: The tax authority issues a dedicated 10-digit GMT tax identification number that remains legally distinct from the enterprise standard corporate tax ID.
All information returns, QDMTT filings, and treasury payment orders for minimum top-up taxes must reference this specific GMT tax code.
Operational compliance risk
The Decree requires the dedicated GMT tax code for filing and paying. A payment made under a standard corporate tax ID may be credited to the wrong obligation and need a correction procedure, with a risk of late payment interest in the meantime.
Step 4: Reconcile VAS with IFRS under Form 01/TM
The most demanding technical component of the GMT compliance sequence is preparing Form 01/TM, which explains differences of EUR 1 million or more between the local accounts and the figures used for the group’s consolidated statements.
OECD Pillar Two rules and the Decree mandate that GloBE net income or loss must be derived from the financial accounting standard used to prepare the UPE consolidated financial statements (IFRS or another accepted financial accounting standard, such as US GAAP). Conversely, local Vietnamese entities record transactions under Vietnamese Accounting Standards (VAS) and Circular 99/2025/TT-BTC (which replaced Circular 200/2014/TT-BTC from fiscal year 2026). Form 01/TM lists, for each constituent entity, the items where local-standard figures differ from the reporting package used for the UPE consolidated statements by EUR 1 million or more, with the reason. The table below shows five typical sources of difference, not fields of the form. A group that applies the transition relief does not complete the explanation table.
| Adjustment Category | VAS Treatment | GloBE / IFRS Treatment |
|---|---|---|
| Fixed Asset Depreciation | Historical cost basis under current fixed-asset depreciation regulations | Fair value adjustments and economic useful life modeling |
| Revenue Recognition | Risk-and-reward transfer thresholds under current accounting standards | IFRS 5-step control transfer criteria under IFRS 15 |
| Balance Sheet Provisions | Specific invoice aging rules for doubtful trade debts | Expected Credit Loss (ECL) forward-looking model under IFRS 9 |
| Mandatory GloBE Adjustments | Standard local P&L inclusion of dividends and penalties | Exclusion of intra-group dividends, equity gains, and fines |
| Functional Currency | Bookkeeping and filings executed in VND | Functional currency of UPE; tax payable in VND or, by election, the UPE currency |
FDI enterprises must avoid treating Form 01/TM as an annual retrospective exercise. Continuous quarterly data bridging works better. Corporate groups that have integrated VAS-to-IFRS conversion services experience substantially fewer reconciliation variances during tax audits.
Step 5: Submit QDMTT Returns and Remit Tax via eTax
Formal GMT compliance requires concurrent electronic filing of two primary declarations alongside technical attachments:
- Form 01/TKTT-QDMTT: Information return of the Vietnamese constituent entity under the Global Minimum Tax rules. It is a separate document from the group-level GloBE Information Return.
- Form 01/TNDN-QDMTT: Corporate Income Top-up Tax Return. Section I computes the top-up tax; Section II allocates it among the Vietnamese constituent entities using an allocation key chosen by the filing entity. Where liability relief brings the Vietnamese top-up tax to zero, Section II is left blank.
- Form 01/TM: Reconciliation statement explaining differences between financial accounting standards.
- Mandatory Attachments: The group-level GloBE Information Return, due 15 months after fiscal year-end (18 months for the first year) (general group information, group structure, and ETR and top-up tax data for Vietnamese constituent entities, unless the group files none in any jurisdiction) and the financial data report of each constituent entity used for the UPE consolidated financial statements.
For QDMTT, Article 6.1 of Resolution 107/2023/QH15 sets a single deadline for the information return, the top-up tax return with Form 01/TM, and payment:
| Return Type (QDMTT) | First Reporting Year (FY2024) | Subsequent Reporting Years (FY2025 Onward) |
|---|---|---|
| Information Return (Form 01/TKTT-QDMTT) | No later than 12 months after fiscal year-end | No later than 12 months after fiscal year-end |
| QDMTT Top-up Tax Return (Form 01/TNDN-QDMTT) | No later than 12 months after fiscal year-end | No later than 12 months after fiscal year-end |
| Top-up Tax Treasury Remittance | No later than 12 months after fiscal year-end | No later than 12 months after fiscal year-end |
Unlike standard CIT, which enforces quarterly provisional remittances covering at least 80% of annual liabilities, the Global Minimum Tax operates on a single annual settlement model. However, any tax balance unpaid past the 12-month deadline incurs daily late payment interest.
Groups under the Income Inclusion Rule (IIR) file Forms 01/TKTT-IIR and 01/TNDN-IIR, due within 18 months of fiscal year-end for the initial year and 15 months for later years (Article 6.2, Resolution 107/2023/QH15). The group-level GloBE Information Return follows the same 18/15-month deadline.
Step 6: Elect the Transitional CbCR Safe Harbor
The Transitional CbCR Safe Harbor applies to fiscal years beginning on or before December 31, 2026, excluding any fiscal year ending after June 30, 2028 (Article 11.1, Decree 236/2025/ND-CP). A group that passes one of the tests (de minimis, simplified ETR, routine profits or a loss) on its Qualified Country-by-Country Report owes no local top-up tax; the thresholds are set out in the implementation guide.
Under Article 11.8.d of Decree 236, the transition relief does not apply in a country where the group had constituent entities but did not apply the relief in the previous fiscal year. Keep the Qualified CbCR and the calculations behind each test on file to support the claim.
Penalty Framework and Transitional Relief Provisions
GMT compliance is enforced under Decree 125/2020/ND-CP on administrative tax penalties and Law on Tax Administration No. 108/2025/QH15.
| Non-Compliance Category | Applicable Sanction | Legal Basis |
|---|---|---|
| Late Filing of Returns | Fines from formal warning up to VND 25,000,000 across 5 progressive delay tiers (1-5 days to over 90 days); organization level. The top tier applies only where tax is due and paid in full, with late-payment interest, before an inspection decision or violation record; otherwise the delay is treated as tax evasion | Art. 13, Decree 125 |
| Late or Missing Notification of the Constituent Entity Responsible for Filing | Formal warning for late notification; VND 1,000,000 to 2,000,000 for failure to notify; organization level | Art. 10, Decree 125 (supplemented by Decree 310/2025/ND-CP) |
| Incorrect Declaration Resulting in Tax Shortfall | Administrative fine of 20% of underdeclared top-up tax amount | From 1 July 2026: Article 44.3.b, Law 108/2025/QH15; earlier conduct: Art. 16, Decree 125 |
| Overdue Remittance of Top-up Tax | Daily interest assessment of 0.03% per day on overdue balance | Article 16, Law 108/2025/QH15 |
| Transitional Penalty Relief (fiscal years starting on or before 31/12/2026 and ending no later than 30/6/2028) | No administrative penalty for specified conduct, such as late nomination notice, tax registration up to 90 days late, returns filed up to 90 days late, or filing errors that do not understate tax | Art. 11.4, Decree 236 |
Transitional penalty relief covers only the conduct listed in Article 11.4 of Decree 236. It does not generally waive the 20% penalty for understated tax: an understatement is relieved only where the transactions are fully recorded in the books and invoices and the full tax and late payment interest were paid before a penalty decision. Late payment interest of 0.03% per day remains mandatory on all underpaid tax amounts and cannot be forgiven under transitional relief.
Master Filing Calendar and Form Directory
| Form | Official Document Title | Filing Deadline | Receiving Authority |
|---|---|---|---|
| Form 01/TB-ĐVHT | CE Nomination Notification | Within 30 days after fiscal year-end (FYE) | Tax authority (in person, by post or electronic) |
| Form 01-ĐKTĐ-ĐVHT | GMT Tax Code Registration Application | Within 90 days after FYE | Tax authority via electronic portal |
| Form 01/TM | Explanation of differences (EUR 1 million or more) between local and group accounting figures | Submitted with the QDMTT returns (12 months) | Tax authority via electronic portal |
| Form 01/TKTT-QDMTT | Information return of the Vietnamese constituent entity | Within 12 months after FYE | Tax authority via electronic portal |
| Form 01/TNDN-QDMTT | QDMTT Top-up Tax Return | Within 12 months after FYE | Tax authority via electronic portal |
| Safe Harbor Dossier | Qualified CbCR & safe harbor test calculations | Per the QDMTT filing deadline (12 months) | Tax authority via electronic portal |
Global Minimum Tax compliance operates at the direct nexus of local corporate taxation, transfer pricing documentation, and international financial reporting. Once local QDMTT obligations are settled, foreign investors retain full rights for profit repatriation through authorized foreign investment capital accounts (formerly DICA).
ICLV’s tax compliance team prepares the Form 01/TM reconciliation, models the CbCR safe harbor and files under Decree 236/2025/ND-CP. Contact our Certified CPAs and tax compliance team before the 30-day nomination window closes.
