OECD Pillar Two in Vietnam.

For global information on OECD Pillar Two and the global minimum tax for multinational groups in all markets, see Acclime Group’s guide.

Vietnam has adopted the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) Rules, known locally as the Global Minimum Tax (GMT), introducing a 15% global minimum effective tax rate for large multinational enterprise (MNE) groups. The rules were enacted by the National Assembly through Resolution 107/2023/QH15 and are detailed in Decree 236/2025/NĐ-CP. They apply for fiscal years beginning on or after 1 January 2024 and interact closely with Vietnam’s existing corporate income tax (CIT) regime.

At this stage, Vietnam has adopted two of the GloBE charging mechanisms: the Qualified Domestic Minimum Top-up Tax (QDMTT) and the Income Inclusion Rule (IIR). The Undertaxed Payments Rule (UTPR) has not yet been adopted.

This guide summarises Vietnam’s implementation status, filing obligations and the local considerations most relevant to in-scope groups.

At a glance

Local summary

Vietnam’s Global Minimum Tax (GMT) (its implementation of the OECD Pillar Two rules) interacts closely with the existing corporate income tax (CIT) regime. While Vietnam continues to offer tax incentives such as tax holidays, reduced CIT rates and investment incentives, these benefits may be partially neutralised under the GMT.

If the effective tax rate (ETR) of an entity falls below 15%, a Top-up Tax is applied under the Qualified Domestic Minimum Top-up Tax (QDMTT). As a result, tax incentives no longer reduce the overall tax burden below the global minimum rate.

Scope and key concepts

The GloBE Rules apply to an MNE group with consolidated annual revenue of at least EUR 750 million in at least two of the four fiscal years immediately preceding the relevant fiscal year.

Local deviations

There are no local deviations from the OECD GloBE architecture.

Compliance and filing obligations

The reporting requirements under the QDMTT are as follows:

• Appointment of a filing Constituent Entity (CE): Where a group has more than one CE in Vietnam, a CE is appointed to be responsible for GMT compliance. In practice, a conservative approach is taken, with each qualifying entity still submitting a notification.
• Tax code registration: The relevant CE registers for a tax code.
• QDMTT filing:
  • GloBE Information Return (GIR)
  • Supplementary Corporate Income Tax Return
  • Reconciliations and explanations of differences in accounting standards
  • The reporting pack of the CE used in preparing the group financial statements

Tax incentive impact

Pillar Two reduces the effectiveness of Vietnam’s existing local tax incentives, such as tax holidays, reduced corporate income tax (CIT) rates and other preferential regimes. While these incentives remain available under domestic law, they may no longer reduce the overall tax burden below the 15% global minimum effective tax rate.

If the effective tax rate falls below this threshold, a Top-up Tax is applied (for example, under the QDMTT), effectively neutralising the benefit of such incentives.

Key local issues

• Transitional relief: There are no penalties for late filing, non-compliance or incorrect reporting during the Transitional Period, that is, for fiscal years beginning before 31 December 2026 and ending before 30 June 2028.
• After the transitional period: Once the Transitional Period ends, penalties will be imposed in accordance with prevailing law.

Source links

• Resolution 107/2023/QH15: National Assembly resolution applying Top-up Tax under the GloBE rules. Official text (Government Portal, Vietnamese)
• Decree 236/2025/NĐ-CP: implementing decree detailing the QDMTT and IIR, effective 15 October 2025. Full text (Government Portal, Vietnamese)

Local contact

For advice on how the Global Minimum Tax applies to your group’s Vietnamese operations, please contact Acclime Vietnam about their tax services.