Official Letter No. 372/TCT-CS regarding the implementation of the global minimum tax policy.

Regarding this matter, the General Department of Taxation provides the following opinions:

Regulations on Qualified Domestic Minimum Top-up Tax (QDMTT)

Entities or groups of entities constituting a multinational enterprise (MNE) group, as stipulated in Article 2 of this Resolution, that conduct production and business activities in Vietnam during the financial year must comply with the regulations on the Qualified Domestic Minimum Top-up Tax.

In cases where such entities or groups of entities in Vietnam generate income under the global minimum tax regulations and the effective tax rate in Vietnam falls below the minimum tax rate, the Qualified Domestic Minimum Top-up Tax in Vietnam shall be determined in accordance with Clauses 2 and 9 of this Article.

Entities in Vietnam that are part of a multinational enterprise group subject to the global minimum tax regulations and qualify for corporate income tax incentives shall continue to benefit from such incentives as prescribed by the current corporate income tax laws. However, pursuant to Articles 2 and 4 of Resolution No. 107/2023/QH15, after applying the tax incentives, if the effective tax rate of the group in Vietnam remains below the minimum tax rate of 15%, a supplementary corporate income tax must be paid under the global minimum tax regulations.

On December 31, 2024, the Government issued Decree No. 182/2024/NĐ-CP, stipulating the establishment, management, and utilization of the Investment Support Fund to provide assistance to enterprises that meet the criteria and conditions for support from the Fund.

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