Regulatory Update: Decision No. 3563/QĐ-BTC on New Global Minimum Tax (GMT) Administrative Procedures

Decision No. 3563/QĐ-BTC, issued by the Ministry of Finance on October 21, 2025, announces 04 new administrative procedures within the tax administration field. These procedures are mandatory for Multinational Enterprise (MNE) groups subject to the Global Minimum Tax (GMT) rules, detailing the process for declaration and payment of the top-up tax (QDMTT and IIR) as specified in Decree 236/2025/NĐ-CP.

Key Highlights

• Scope of Application: The procedures apply to constituent entities of MNE groups, including Joint Ventures and partially-owned entities, responsible for declaring and paying supplementary Corporate Income Tax (CIT).
• Key Procedures (GMT Updates): The Decision announces four new administrative procedures related to GMT:
  • Notification: Informing the tax authority of the responsible Constituent Entity (CE) and the list of CEs subject to Resolution 107/2023/QH15.
  • Registration/Change: Tax registration/change of registration information for the responsible CE.
  • QDMTT Filing: Filing the supplementary CIT for the Qualified Domestic Minimum Top-up Tax.
  • IIR Filing: Filing the supplementary CIT for the Income Inclusion Rule.
• Effective Date/Deadline:
  • The Decision is effective from the date of signing (October 21, 2025).
  • The notification deadline is 30 days after the end of the reporting fiscal year.
  • The initial tax registration deadline is 90 days after the end of the reporting fiscal year.
• Executing Agency: Chi cục Thuế Doanh nghiệp lớn (Large Enterprise Tax Sub-Department)

This summary is provided for reference purposes only and highlights key aspects of Decision No. 3563/QĐ-BTC. For full and legally binding content, please refer strictly to the attached official document.

Attached File:

📎 Decision No. 3563/QĐ-BTC (Official PDF – signed & sealed)