Regulatory Update: Decree No. 236/2025/ND-CP on Detailed Regulations for Implementing Global Minimum Tax

Decree No. 236/2025/NĐ-CP, issued by the Government on August 29, 2025, details the implementation of the Global Minimum Tax (GMT) rules in Vietnam, specifically the Income Inclusion Rule (IIR) and the Qualified Domestic Minimum Top-up Tax (QDMTT). This Decree applies to multinational enterprise (MNE) groups with consolidated revenue exceeding the 750 million EUR threshold and establishes guidelines for determining the tax base, calculating the top-up tax, and specifying filing deadlines.

Key Highlights

• Scope of Application and Taxpayers: The Decree applies to constituent entities of an MNE group with consolidated revenue of at least 750 million EUR in at least two of the four immediately preceding fiscal years. It outlines detailed rules for calculating the equivalent EUR threshold for non-standard fiscal years and in cases of mergers or demergers.
• Mechanism of Application (Chapter II):
  • QDMTT (Qualified Domestic Minimum Top-up Tax): Applies to constituent entities operating and residing in Vietnam , ensuring the effective tax rate in Vietnam reaches the 15% minimum.
  • IIR (Income Inclusion Rule): Applies to ultimate parent entities, partially-owned parent entities, and intermediate parent entities in Vietnam that hold direct or indirect ownership in low-taxed foreign constituent entities.
• Compliance Deadlines (Kê khai, Nộp thuế):
  • Tax Registration: The responsible constituent entity must file the initial tax registration request no later than 90 days after the end of the reporting fiscal year.
  • Filing and Payment: The deadline for filing the Top-up Tax Return (Tờ khai thuế TNDN bổ sung) and paying the tax is 18 months after the end of the fiscal year for the first reporting year, and 15 months for subsequent years.
• Effective Date: The Decree is effective from October 15, 2025, and is applied starting from the 2024 fiscal year (fiscal years beginning on or after January 1, 2024).