On 29 August 2025, Vietnam formally introduced Decree No. 236/2025/ND-CP to implement the global minimum tax (GMT), also known as the top-up tax, in line with the OECD’s Pillar Two/GloBE framework. The Vietnamese government will implement the decree from 15 October 2025 to align with international tax reform efforts. It requires large multinational enterprise (MNE) groups to pay a minimum level of tax on profits earned in Vietnam. The rules apply retroactively to fiscal year 2024, so businesses should act quickly.
Table of contents:
- Who is affected by Vietnam’s Top-Up Tax?
- Designate a constituent entity to declare and pay Top-up Tax under the GloBE rules
- Initial Tax Code Registration
- Tax filing deadlines
- Practical Considerations: Currency and Payments
- Understanding the transitional safe harbors
Who is affected by Vietnam’s Top-Up Tax?
Your company may fall under Decree 236 if it meets the following criteria:
- A Constituent Entity (CE) of a Multinational Enterprise (MNE) group; and
- The MNE group has consolidated global revenue that is greater than or equal to EUR 750 million in at least 2 of the 4 preceding fiscal years
Designate a constituent entity to declare and pay Top-up Tax under the GloBE rules
Each in-scope Multinational Enterprise (MNE) group must designate one of its Vietnamese Constituent Entities (CEs) as the Filing Entity under Decree 236. This designated entity handles the preparation and submission of the group’s top-up tax return and related compliance filings under the Qualified Domestic Minimum Top-up Tax (QDMTT) regime. MNE groups must complete this designation within 30 days after the fiscal year-end of the Ultimate Parent Entity (UPE), not the Vietnamese subsidiary’s year-end.
Initial Tax Code Registration
After designating the Filing Entity, the MNE group must register it for a special tax identification code specifically for QDMTT compliance. This code differs from the standard corporate tax number and is used only for filings under Vietnam’s global minimum tax regime. The group must complete this registration within 90 days after the fiscal year-end of the Ultimate Parent Entity (UPE).
For the first reporting year (FY2024), a transitional rule applies. If the fiscal year ends on or before 30 June 2025, the group must register the Filing Entity within 90 days of 15 October 2025, the effective date of Decree 236. In all cases, they must complete the registration before the statutory tax filing deadline. Registering early helps avoid access issues and ensures timely compliance with the new rules.
Tax filing deadlines
All relevant returns must be filed in accordance with the deadlines below:
| Return Type | FY2024 Deadline | FY2025+ Deadline |
|---|---|---|
| QDMTT Top-up Tax Return | 12 months after FYE | 12 months after FYE |
| MNE Group Info Return | 18 months after FYE | 15 months after FYE |
| Income Inclusion Return (IIR) | 18 months after FYE | 15 months after FYE |
Currency and Payments
- Reporting Currency: The MNE Information Return must be submitted in the UPE’s reporting currency.
- Payment Currency: Tax must be paid in Vietnamese Dong (VND). If calculated in a foreign currency, payment in that currency may be allowed. Otherwise, convert to VND using the average bank transfer rate on the filing date.
Understanding the transitional safe harbors
Safe harbors are transitional relief provisions that allow for simplified compliance or potential exemption from the top-up tax for certain fiscal years. These apply to fiscal years starting on or before 31 December 2026, and ending no later than 30 June 2028.
Your top-up tax liability may be reduced to zero if any of the following apply:
- The MNE Group has a qualified country-by-country report in which: Total Revenue is less than EUR 10M and profit is less than EUR 1M or loss
- Simplified effective tax rate (ETR): greater than or equal to 15% (2023–2024), 16% (2025), 17% (2026)
- Profit is less than or equal to substance-based income exclusion, which includes tangible assets and payroll costs
- Loss reported in qualified CbCR.
If you need assistance, RBA WTS Vietnam is ready to provide expert guidance to meet your needs. Please contact us for support or a personalized consultation.
