Decree 236/2025/ND-CP implements Vietnam’s Global Minimum Tax, effective October 15, 2025. Multinational groups with EUR 750 million+ in consolidated revenue face a 15% minimum effective tax rate enforced through two mechanisms: QDMTT (domestic top-up) and IIR (foreign subsidiary top-up).
The Vietnam tax system overview covers how GMT fits within the broader FDI compliance framework.
Key takeaways
- Decree 236/2025/ND-CP targets multinational groups with EUR 750 million+ revenue, effective for fiscal years from January 1, 2025. Transitional simplified ETR safe harbors: 15% (FY2024), 16% (FY2025), 17% (FY2026).
- Vietnam’s QDMTT collects domestic top-up tax first — before the parent jurisdiction can impose IIR charges. No double collection.
- Safe harbor provisions can reduce top-up tax to zero: de minimis thresholds (revenue < EUR 10 million and profit < EUR 1 million) or simplified ETR tests above the applicable threshold.
- Deadlines: Filing CE notification within 30 days after fiscal year-end, GMT tax registration within 90 days, returns filed 12–18 months after fiscal year-end.
OECD Qualified Status: What It Means for FDI Compliance
Vietnam achieved OECD transitional qualified status on August 18, 2025 — meaning its QDMTT and IIR frameworks meet Pillar Two standards. Three practical consequences:
- Vietnam collects first. QDMTT takes priority over parent jurisdiction IIR charges. MNE groups avoid double collection.
- Single filing accepted. Consolidated data filed in Vietnam satisfies both QDMTT and IIR reporting — no parallel submissions.
- Predictable enforcement. Transitional penalty relief covers FY2024-2028 for minor documentation gaps corrected within 90 days.
Note: OECD transitional qualified status recognition is subject to Inclusive Framework assessment procedures. The legislative foundation traces to Resolution 107/2023/QH15 (November 2023).
Scope: Which MNE Groups Are Affected
MNE groups fall under GMT obligations if consolidated revenue hits EUR 750 million (~VND 20,000 billion) in at least two of four preceding fiscal years. Testing spans four years, so temporary dips below the threshold do not immediately remove the group from scope.
GMT matters most when Vietnamese subsidiaries benefit from CIT incentives — preferential rates of 10% or 17% can push the effective tax rate below the 15% floor, triggering QDMTT top-up. Groups enjoying Economic Zone or High-Tech Park incentives should model the impact immediately.
Consolidation follows accounting standards used by the Ultimate Parent Entity (UPE). Decree 236 operates through two mechanisms:
- QDMTT (primary): Vietnam collects domestic top-up tax on Vietnamese entities when their effective tax rate drops below 15%. This prevents foreign jurisdictions from collecting first.
- IIR (secondary): When Vietnamese parent entities hold subsidiaries in low-tax jurisdictions, Vietnam imposes top-up tax on those foreign operations.
Credit mechanisms between the two systems prevent double taxation.
Initial Phase Exclusion (FY2024-2028)
Smaller MNE groups receive transitional relief. Groups qualify if constituent entities operate in no more than six jurisdictions and total tangible assets are under USD 50 million outside Vietnam. Full QDMTT compliance applies after FY2028.
Maintaining this exclusion requires annual documentation: business plans, capital deployment schedules, and operational milestones. Tax authorities review these periodically.
Safe Harbor Provisions
Safe harbors allow MNE groups to bypass complex calculations — the top-up tax drops to zero if one of three tests is met (available through June 30, 2028):
| Test | Threshold |
|---|---|
| De minimis | Revenue < EUR 10 million and profit < EUR 1 million (or loss) |
| Simplified ETR | Effective rate ≥ 15% (FY2024), 16% (FY2025), 17% (FY2026) |
| Transitional safe harbor | Temporary relief during initial implementation |
Elections require annual confirmation with supporting documents: financial statements, tax returns, and Country-by-Country Reports (CbCR). When a subsidiary qualifies in one jurisdiction, the group does not face conflicting assessments elsewhere — Vietnam’s safe harbor aligns with OECD standards.
IIR Top-Up Tax Ordering
When top-up tax applies, collection follows a strict priority:
- QDMTT: Vietnam collects on Vietnamese entities first
- Primary IIR: Parent jurisdiction collects on remaining low-tax operations
- Secondary IIR: Intermediate holding companies collect through the ownership chain
- UTPR: Remaining amounts allocated through deduction denial across group members
Credits offset amounts collected by multiple jurisdictions to maintain the 15% floor.
Financial Reporting Impact Under Decree 236
GloBE adjustments require recalculating existing VAS-compliant figures. The gap between VAS and GloBE standards creates additional work — particularly for equity-method investments, foreign currency translation, and consolidation scope.
Key adjustments:
- Equity method: Associated companies and joint ventures need GloBE-specific recalculation. VAS recognizes investment income differently from GloBE methodology, requiring parallel calculations for the same entities.
- Currency translation: Functional currency uses OECD-prescribed rates — not the VND-based rates used for VAS reporting. Separate FX translation workpapers are necessary.
- Consolidation scope: Investment entities and special purpose vehicles that VAS might exclude now fall within GloBE inclusion criteria.
- Timing: Recognition periods between financial statements and tax calculations must align. Mis-timed revenue recognition is a common audit trigger.
QDMTT Calculations and Loss Treatment
Losses do not trigger top-up tax. Net operating losses eliminate liability for the current period, and prior-period losses carry forward to offset future positive adjustments. De minimis and safe harbor qualifications also produce zero top-up results.
FDI enterprises should track losses carefully across fiscal years. Detailed records of loss origins, utilization patterns, and remaining carry-forward amounts are essential — Vietnamese tax authorities verify these during examinations.
One critical point: QDMTT calculations must tie directly to the Country-by-Country Report (CbCR). Tax authorities cross-check both filings systematically. Discrepancies trigger audit flags. Maintaining a single source of truth across QDMTT returns and CbCR prevents compliance surprises.
Documentation Requirements
The following records are the first items auditors request during GMT examinations:
- Calculation worksheets for all GloBE adjustments
- Variance reconciliations between financial statements and tax figures
- Source documents, contracts, and legal agreements supporting tax positions
- Complete audit trails enabling independent verification
Incomplete documentation is the #1 cause of QDMTT reassessments. Quarterly reconciliations catch issues before they compound at year-end.
Registration, filing, and deadlines
Registration and filing follow a strict calendar. Miss a deadline and penalties start at VND 40 million (~USD 1,600) — no informal grace periods.
Note: FYE = Fiscal Year-End
| Requirement | Timeline | Tax forms (IIR) | Tax forms (QDMTT) |
|---|---|---|---|
| Filing CE Appointment: Vietnamese CE list + election form | FYE + 30 days | Form No. 01/TB-DVHT | |
| Tax registration: All Vietnamese CEs within the MNE group | FYE + 90 days | Form No. 01-DKTD-DVHT | |
| GMT filing dossier | |||
| Informational return: Group-wide financial and tax data | FYE + 12 months | Form No. 01/TKTT-IIR | Form No. 01/TKTT-QDMTT |
| Top-up tax return: Vietnam-specific calculations | Form No. 01/TNDN-IIR | Form No. 01/TNDN-QDMTT | |
| Variance explanation from accounting principles | Form No. 01/TM | Form No. 01/TM | |
| Financial data reports per CE | Per home jurisdiction | Per home jurisdiction | |
| Consolidated financial statements of UPE | Per home jurisdiction | Not required | |
| GloBE Informational return | FYE + 15 months (18 months for first year) | Not required | Per home jurisdiction |
For the complete filing walkthrough — including eTax portal registration, Form 01/TM reconciliation requirements, and safe harbor claim procedures — see our dedicated GMT filing and registration guide.
Penalty Framework
| Violation | Penalty |
|---|---|
| Late filing | 20% of tax liability or minimum VND 40 million (~USD 1,600) |
| Late payment | 0.03% per day of outstanding amounts |
| Inaccurate reporting | 10-30% of additional assessments plus interest |
| Non-compliance | Suspension of investment incentives and business licenses |
Transitional penalty relief (FY2024-2028) covers: late notification up to 90 days, incorrect filings not causing underpayment, late returns within 90 days with no tax payable, and missing documentation within 90 days when no liability arises.
GMT implementation directly impacts FDI tax strategies. Enterprises benefiting from CIT incentives must model whether the effective rate falls below 15% and triggers QDMTT top-up.
Transfer pricing documentation feeds into GloBE calculations — intercompany pricing that shifts profits between jurisdictions affects jurisdiction-level ETR. After QDMTT settlement, remaining profits follow standard repatriation procedures through the DICA.
This article reflects Global Minimum Tax regulations as of March 2026 under Decree 236/2025/ND-CP, Resolution 107/2023/QH15, and Law on Tax Administration 38/2019/QH14. GMT rules are subject to OECD Inclusive Framework updates and implementing circulars — consult qualified tax advisors for compliance guidance specific to each MNE group’s operations.
