Vietnam mandates Global Minimum Tax (GMT) filings starting FY2024 for multinational enterprise (MNE) groups exceeding EUR 750 million in global consolidated revenue, governed by Decree 236/2025/ND-CP. Unlike routine corporate tax obligations handled by local tax departments, the GMT architecture centralizes all reporting directly to the General Department of Taxation (GDT).
Corporate taxpayers face aggressive, multi-layered deadlines. Chief Financial Officers must transition from standard statutory reporting into complex global data consolidation, executing a highly choreographed sequence of 10-digit tax code registrations, entity nominations, and international accounting reconciliations.
This guide provides a practical, step-by-step roadmap for filing the Global Minimum Tax in Vietnam, mirroring the structured protocols utilized by top-tier compliance teams.
Executive Key Takeaways
- Strict Timelines: The compliance clock starts ticking immediately. Entity nomination requires action within 30 days of the fiscal year-end, followed by tax code registration within 90 days.
- Specific Portals: All filings occur strictly through the national eTax portal (thuedientu.gdt.gov.vn). Paper submissions at the provincial level are obsolete for GMT purposes.
- Filing Deadlines: Standard Qualified Domestic Minimum Top-up Tax (QDMTT) returns fall due exactly 12 months after the fiscal year-end. The Income Inclusion Rule (IIR) provides an 18-month window for the first transitional year.
- Strategic Risk: The conversion from VAS to international accounting standards (IFRS/IAS) poses the highest operational hazard. Form 01/TM explicitly demands documented explanations for all accounting standard variances underpinning the GloBE calculations.
Step 1: Determine Applicability & Consolidation Framework
The Global Minimum Tax framework permanently alters how Vietnam taxes large-scale foreign investment. The mechanism treats the entire global group as a unified taxable entity before pushing obligations down to local operational levels.
To trigger the GMT obligations in Vietnam, the ultimate parent entity (UPE) must report global consolidated revenues reaching or exceeding EUR 750 million in at least two of the four preceding fiscal years. Once the MNE group crosses this threshold, every subsidiary, branch, or permanent establishment operating in Vietnam qualifies as a constituent entity (CE). All constituent entities automatically fall under the scope of the local top-up tax rules, completely bypassing regional investment incentives or previously acquired tax holidays. Under Resolution 107/2023/QH15, these obligations apply universally to both the QDMTT and the IIR.
Finance teams must immediately review the ultimate parent entity’s financial statements. If the revenue threshold is confirmed, you must inventory all local Vietnamese constituent entities to prepare for the consolidation and nomination phase.
Step 2: Nominate the Constituent Entity (Form 01/TB-DVHT)
Because an MNE group frequently operates multiple distinct legal entities inside Vietnam (for example, separate manufacturing plants, trading companies, and logistics arms), the government avoids redundant paperwork through consolidation. The MNE group must legally nominate a single constituent entity to act as the official filing representative for all Vietnamese operations.
This nomination process operates on an exceptionally tight 30-day timeline. The group must formalize this decision by executing Form 01/TB-DVHT (Notification of Constituent Entity Designation) within 30 days from the end of the fiscal year.
Decree 236/2025/ND-CP enforces a harsh fallback protocol for indecisive corporate groups. If an MNE fails to submit Form 01/TB-DVHT within the 30-day window, the GDT automatically appoints the constituent entity holding the largest total asset value as the mandatory filing agent. This automated selection frequently disastrously appoints asset-heavy manufacturing arms lacking the sophisticated accounting personnel necessary to handle complex international tax filings. Executive management should actively nominate the entity possessing the strongest accounting and compliance infrastructure.
Step 3: Register the Dedicated GMT Tax Code (Form 01-DKTD-DVHT)
Following a successful nomination, the designated filing entity must acquire a dedicated GMT tax code. This registration must finalize within 90 days from the fiscal year-end. For companies with a standard calendar fiscal year ending December 31, 2024, the absolute deadline to secure this code is March 31, 2025.
To initiate this process, the nominated entity must file Form 01-DKTD-DVHT through the General Department of Taxation’s electronic transaction portal (iHTKK or eTax system at thuedientu.gdt.gov.vn).
The GDT will issue a special ten-digit code that functions completely independently of the company’s existing Enterprise Registration Certificate (ERC) or standard corporate tax ID. The designated entity uses this new code exclusively for submitting the GloBE Information Return, declaring top-up taxes, and remitting payments to the central state budget. Do not attempt to use your standard corporate tax code to remit GMT payments, as this guarantees misallocation of funds and subsequent late payment penalties.
Step 4: Reconcile VAS with IFRS & Calculate the GloBE ETR
Gathering the standard compliance forms merely represents the surface-level bureaucratic requirement. The deepest technical trap within the entire filing process involves the reconciliation of accounting standards.
The GloBE calculations fundamentally rely on the acceptable financial accounting standard utilized by the ultimate parent entity—almost exclusively International Financial Reporting Standards (IFRS) or recognized equivalents like US GAAP. Conversely, local Vietnamese constituent entities maintain their statutory books and file standard corporate taxes strictly using Vietnamese Accounting Standards (VAS).
Decree 236/2025/ND-CP aggressively targets this disconnect via Form 01/TM. The filing entity must submit this mandatory written explanation detailing every material discrepancy between the local VAS records and the international standards utilized for the top-up tax computation. Auditors intensely scrutinize this reconciliation bridge. Companies must construct a systematic tracking mechanism capable of translating local depreciation schedules, revenue recognition timing, and inventory valuations directly into the UPE’s global framework. Failing to clearly document the transition from VAS net income to GloBE income triggers immediate audit interventions and potentially forces a complete recalculation of the baseline effective tax rate (ETR).
Step 5: Submit Returns via eTax Portal (Forms 01/TKTT & 01/TM)
The final submission data package maps the entire global corporate structure, identifies every constituent entity worldwide, and discloses their respective effective tax rates.
The filing deadlines dictate a rigid operational calendar:
- QDMTT Returns: The filing entity must submit Form 01/TKTT-QDMTT (Information Return) and Form 01/TNDN-QDMTT (Top-up Tax Declaration) alongside the Form 01/TM reconciliation explicitly no later than 12 months after the fiscal year-end. Consequently, for a fiscal year ending December 31, 2024, the absolute deadline lands on December 31, 2025.
- IIR Returns: The Income Inclusion Rule utilizes a slightly modified timeline. Recognizing the extreme complexity of coordinating global tax data, the initial IIR filing (Forms 01/TKTT-IIR and 01/TNDN-IIR) for the very first transitional year extends to 18 months post-fiscal year-end. For all subsequent fiscal years, the IIR deadline compresses to 15 months.
After submitting the full documentation package via the eTax portal, you must immediately route the calculated top-up tax payment directly to the central state budget using the specialized 10-digit GMT tax code acquired in Step 3.
Step 6: Navigate Penalties & Claim Transitional Safe Harbors
The government acknowledges the monumental operational shift required to comply with Pillar Two rules. To prevent widespread non-compliance during the initial implementation phase, regulators deployed a temporary safety net.
Groups can utilize the Transitional CbCR Safe Harbor to effectively reduce their top-up tax to zero in specific jurisdictions. By passing the simplified ETR test (achieving a safe harbor ETR of at least 15% in 2024, 16% in 2025, and 17% in 2026), the routine profits test, or the de minimis test utilizing data directly from qualified Country-by-Country Reports, subsidiaries can largely bypass the exhaustive GloBE calculation mechanics.
Additionally, the transitional penalty relief period applies exclusively to fiscal years 2024, 2025, and 2026. Authorities will waive standard administrative fines for errors within the GloBE computation, provided those errors stem specifically from genuine differences in accounting standards or good-faith misinterpretations.
[!WARNING] RISK ALERT: Standard Late Penalties Survive the Safe Harbor The transitional relief explicitly waives administrative fines for calculation discrepancies—but completely ignores missing deadlines or payment deficits. Under the Tax Administration Law (Law 38/2019/QH14), any underpaid top-up tax amount silently accumulates late payment interest at a punishing rate of 0.03% per day (approximately 11% annually) starting from the original 12-month QDMTT deadline.
Failing to nominate the filing entity within the 30-day window, missing the 90-day tax code registration, or filing the actual returns late triggers the full force of standard administrative penalties under Decree 125/2020/ND-CP, projecting monetary fines climbing up to VND 25 million for procedural delays.
Conclusion & CTA
Navigating Vietnam’s implementation of the Global Minimum Tax demands extreme precision from multinational operators. With massive global revenues exceeding EUR 750 million at stake, failing to aggressively manage the 30-day entity nomination window (Form 01/TB-DVHT) or neglecting the 90-day eTax registration introduces immediate compliance hazards. Above all, corporate finance teams must flawlessly execute the translation between localized VAS books and international reporting frameworks on Form 01/TM, as the government demands granular, documented explanations for every discrepancy.
Securing compliant top-up calculations requires specialized intersectional knowledge of both Vietnamese tax administration logic and multinational IFRS reporting frameworks. For strategic GMT entity nomination advisory, VAS to IFRS reconciliation support, and direct preparation of your firm’s complex GloBE Information Returns, contact our Certified CPAs and tax compliance team. Steven Nguyen and David Nguyen actively guide eligible MNEs through the transitional safe harbor protections and aggressive filing deadlines under Decree 236. Contact us today to secure your local compliance strategy before the initial filing windows close.
