The GIR and global minimum tax filing milestones: a compliance calendar for groups with entities in Vietnam
The short answer
Under Decree No. 236/2025/ND-CP, in-scope multinational groups with constituent entities in Vietnam must meet four main milestones:
Notification of the designated filing entity and the list of constituent entities: within 30 days after the end of the reporting financial year (where the group has two or more entities in Vietnam).
Tax registration to obtain a tax code for the top-up tax obligation.
QDMTT return: no later than 12 months after the end of the financial year.
GloBE Information Return (GIR) and IIR returns: no later than 18 months for the group's first year in scope, and 15 months for subsequent years.
If the group has filed the GIR in a jurisdiction with an exchange-of-information arrangement with Vietnam, the Vietnamese entity files a notification instead of refiling the full GIR.
Why a separate compliance calendar?
The global minimum tax has a very different deadline structure from ordinary CIT:
deadlines follow the financial year of the ultimate parent entity, not that of the Vietnamese subsidiary;
input data is compiled by the parent and its overseas advisers;
the filing comprises several components with different deadlines.
Many foreign-invested businesses stumbled at the very first milestone: the filing-entity notification. It falls just 30 days after year-end, often before the parent has even confirmed whether the group is in scope.
Illustrative calendar (financial year ending 31 December)
Milestone | Action | Deadline (FY2026) |
During the year | Confirm whether the group is in scope (EUR 750 million in at least 2 of the 4 preceding years) | Before 31/12/2026 |
30 days after year-end | Notify the designated filing entity (if two or more entities in Vietnam) and the list of constituent entities | Around 30/01/2027 |
As prescribed | Tax registration for the filing entity (if it does not yet have a tax code for this obligation) | As set out in Decree No. 236/2025/ND-CP |
12 months after year-end | File the QDMTT return: supplementary CIT return, explanation of differences arising from accounting standards, and financial data for each constituent entity | 31/12/2027 |
15 months after year-end (first year: 18 months) | File the GIR, or notify that it has been filed in a jurisdiction with an exchange arrangement; file IIR returns (if any) | 31/03/2028 (first year: 30/06/2028) |
This table is illustrative. Businesses should check Decree No. 236/2025/ND-CP and any amendments at the time, as the Ministry of Finance is proposing changes to certain deadlines to align with new OECD guidance.
What does the GIR contain?
The GIR is a standardised information return based on the OECD template. It covers:
general group information: the ultimate parent, the group structure and constituent entities;
jurisdictional calculations: effective tax rates, top-up tax, exclusions and elections;
allocation of top-up tax between jurisdictions.
Where a group files the GIR in the parent's jurisdiction and that jurisdiction has a GIR exchange arrangement with Vietnam, the Vietnamese entity need only file the prescribed notification. If no suitable exchange mechanism exists, the GIR must be filed in Vietnam.
Common mistakes by foreign-invested businesses
Assuming "the parent handles everything". The parent handles the global GIR, but notification, registration, QDMTT filing and payment in Vietnam are the responsibility of the Vietnamese entity.
Using the subsidiary's financial year to calculate deadlines. All deadlines run from the ultimate parent's financial year.
Failing to designate a filing entity. If the group does not notify on time, the tax authority may designate a constituent entity to file and pay.
Inconsistent data across filings. Figures in the QDMTT return, GIR, CbCR and financial statements must be consistent. Differences arising from accounting standards must be explained.
Ignoring transitional safe harbours. Safe harbours based on a qualified CbCR can significantly simplify calculations in the early years. However, the conditions need careful assessment.
Not keeping up with new rules. The legal framework is being amended continually to keep pace with OECD guidance.
Illustrative case
A European group has three subsidiaries in Vietnam: manufacturing, distribution and services. Its financial year is the calendar year.
At the end of January, the group tax team had still not decided which Vietnamese company would be the filing entity. As a result, the notification was late.
The following year, the group learned from this and set up a joint compliance calendar from October:
it designated the manufacturing company (with the strongest finance team) as the filing entity in advance;
it agreed the data each subsidiary would provide to the parent;
it confirmed that the GIR would be filed in the parent's jurisdiction and then notified in Vietnam.
FAQs
When is the filing-entity notification due?
Within 30 days after the end of the reporting financial year, where the group has two or more constituent entities in Vietnam.
When is the QDMTT return due?
Under Decree No. 236/2025/ND-CP, no later than 12 months after the end of the financial year.
When is the GIR due?
No later than 18 months after the end of the financial year for the group's first year in scope, and 15 months for subsequent years.
If the parent has filed the GIR abroad, must the Vietnamese subsidiary also file it?
If the jurisdiction where the GIR was filed has a qualifying exchange-of-information arrangement with Vietnam, the Vietnamese entity need only file the prescribed notification, not the GIR itself.
Legal basis
Resolution No. 107/2023/QH15 on applying additional CIT under the global anti-base erosion rules.
Decree No. 236/2025/ND-CP (effective 15 October 2025, applying from the 2024 financial year) and its forms.
OECD GloBE Model Rules, GIR template and Administrative Guidance (for reference).
How W&A can help
Global minimum tax compliance means coordinating across many jurisdictions, entities and deadlines. W&A acts as the Vietnam point of contact for multinational groups:
Building a compliance calendar for notifications, registration, QDMTT and GIR filings based on the parent's financial year.
Filing-entity notifications, tax registration and preparation of QDMTT returns in Vietnam.
Coordination with group tax teams and overseas advisers on data, the GIR and transitional safe harbours.
Reconciliation of figures across the QDMTT return, GIR, CbCR and financial statements.
Updates and support on new amendments to Vietnam's global minimum tax rules.
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