Decree No. 236/2025/NĐ-CP dated August 29, 2025, issued by the Hanoi Tax Department on detailed regulations for the implementation of certain provisions of Resolution No. 107/2023/QH15 dated November 29, 2023 of the National Assembly regarding the application of the supplementary corporate income tax under the global anti–base erosion rules, is as follows:

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- Regulations on the application of the supplementary corporate income tax to prevent global base erosion

On August 29, 2025, the Government promulgated Decree No. 236/2025/NĐ-CP detailing certain provisions of Resolution No. 107/2023/QH15 of the National Assembly on the application of the supplementary corporate income tax under the global anti–base erosion rules. This Decree takes effect on October 15, 2025, and applies from the 2024 fiscal year.

This Decree applies to taxpayers who are constituent entities of multinational enterprise (MNE) groups with consolidated revenue of EUR 750 million or more, tax authorities, tax officials, and other agencies, organizations, and individuals involved in the implementation of the global minimum tax rules.

  • Taxpayers and applicable revenue

Taxpayers are constituent entities of an MNE group with consolidated revenue of EUR 750 million or more in at least 2 of the 4 fiscal years preceding the fiscal year in which the tax liability is determined. Such revenue is calculated based on the consolidated financial statements of the ultimate parent entity.

  • Regulations on supplementary corporate income tax

Constituent entities of an MNE group operating in Vietnam are required to apply the Qualified Domestic Minimum Top-up Tax (QDMTT). The MNE group may voluntarily decide on the allocation ofthe top-up tax among its constituent entities in Vietnam.

  • Determination of effective tax rate and top-up tax base

The effective tax rate in Vietnam is calculated for each fiscal year and is determined based on corporate income tax and other similar taxes. The top-up tax base is determined according to net income and deductions for tangible assets and payroll costs.

  • Transitional relief in the initial stage

In the initial stage of international investment activities, the top-up tax under QDMTT in Vietnam may be set as zero if the group satisfies the conditions regarding the number of jurisdictions with constituent entities and the value of tangible assets.

  • Tax declaration and payment

The constituent entity responsible for filing must submit the tax return dossier and fulfill its tax obligations in accordance with regulations. The tax return dossier includes information returns and the supplementary corporate income tax return. The deadlines for filing and tax payment are explicitly stipulated in the Decree.

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