Vietnam to implement Global Minimum Tax: Guidelines for the implementation of Decree 236
Vietnam has introduced Decree 236 to implement Global Minimum Tax (GMT) in accordance with the OECD’s Pillar Two/GloBE framework, thus joining international tax reform efforts. The decree requires large multinational enterprise groups (MNEs) to pay a minimum tax rate on profits earned in Vietnam. It has taken effect on 15 October 2025.
As it already mandatory for companies to implement the decree (No. 236/2025/ND-CP, introduced on 29 August 2025) by mid-October 2025, the Ecovis experts recommend that companies act quickly and familiarise themselves with the key points.
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Impacted taxpayers
Vietnamese taxpayers that meet the following conditions will be subjected to GMT:
- Constituent entity (CE) of a multinational enterprise (MNE)
- MNE with consolidated global revenue of EUR 750 million or more in at least two of the four fiscal years preceding the current fiscal year
However, the decree also clearly stipulates groups of subjects that are excluded. These include the entities mentioned in Resolution 107/2023/QH15 and its appendices, including investment funds, real estate investment organisations or some entities with specific ownership and operation structures.
“We advise you on the implementation of the new minimum tax regulations in Vietnam.”
Trung Pham, Partner, ECOVIS AFA VIETNAM, Da Nang City, Vietnam
Rules for applying the regulations on Qualified Domestic Minimum Top-up Tax (QDMTT)
- Constituent entities or collections of constituent entities of MNE groups that are taxpayers under article 3 of this decree with business operations in Vietnam and residence in Vietnam according to Section I of Appendix II, must apply the regulations on QDMTT.
- In cases where an MNE Group has more than one constituent entity in Vietnam, the filing constituent entity is required to determine the QDMTT liability for all constituent entities of the MNE group in Vietnam. The MNE Group may decide how to allocate the QDMTT payable among its constituent entities in Vietnam and must specify the allocated tax amounts in the supplemental corporate income tax declaration (form no. 01/ TNDN-QDMTT).
- The QDMTT regulations do not apply to constituent entities with undetermined country or territory of residence, permanent establishments with undetermined jurisdictions (stateless companies) and investment entities.
- The fiscal year for applying QDMTT shall be based on the fiscal year of the ultimate parent entity, unless otherwise provided in the decree.
Calculating QDMTT
QDMTT is calculated as follows:
- QDMTT = (top-up tax percentage x excess profit) + additional current top-up tax (if applicable)
Decree 236 also provides detailed instructions on how to calculate QDMTT, income inclusion rules, and detailed regulations on transition and relief.
When Decree 236 comes into force
This decree comes into force on 15 October 2025 and applies from the fiscal year 2024 onward. The fiscal year 2024 shall begin on or after 1 January 2024. In cases where a constituent entity subject to QDMTT follows the fiscal year of its ultimate parent entity and that fiscal year begins in December 2023, this is still considered fiscal year 2024 for the purposes of this decree.
The regulations of this decree shall not be applied to determine tax payable under the Law on Corporate Income Tax.
Deadline for initial taxpayer registration
The filing constituent entity must submit the taxpayer registration application within 90 days after the end of the reporting fiscal year.
In cases where the MNE Group’s fiscal year 2024 ends on or before 30 June 2025, the taxpayer registration deadline is 90 days from the effective date of this decree, but no later than the deadline for filing and paying tax applicable to the group.
