Global minimum tax in Vietnam: QDMTT, IIR and a compliance roadmap for multinational groups
The short answer
From the 2024 financial year, Vietnam applies the global minimum tax under Resolution No. 107/2023/QH15. Detailed guidance is set out in Decree No. 236/2025/ND-CP. It applies to multinational groups with consolidated revenue of EUR 750 million or more in at least 2 of the 4 preceding years.
Vietnam applies two rules:
QDMTT (Qualified Domestic Minimum Top-up Tax): constituent entities in Vietnam with an effective tax rate below 15% must pay top-up tax in Vietnam to reach 15%.
IIR (Income Inclusion Rule): a parent company in Vietnam pays top-up tax on the income of foreign subsidiaries with an effective rate below 15%.
According to the Tax Department, 1,654 groups had filed QDMTT returns in Vietnam by 10 July 2026. Beyond paying tax, groups must also notify the filing entity and submit the GloBE Information Return (GIR).
Why is this a key topic for years to come?
The global minimum tax is not a one-off policy. It is a new tax framework that will accompany large foreign-invested businesses throughout their time in Vietnam, for three reasons:
Traditional tax incentives are partly neutralised. Businesses enjoying CIT exemptions, reductions or a 10% rate may still have to top up to 15% if they belong to an in-scope group.
The rules are still evolving. Vietnam is amending them to align with new OECD guidance. The Ministry of Finance is proposing adjustments to certain filing deadlines and procedures.
Enforcement is stepping up. QDMTT and GIR data will be used for risk management and international exchange of information.
Who is in scope?
Entity | Main obligations |
A Vietnamese constituent entity of an in-scope multinational group (e.g. a foreign-invested subsidiary) | Calculate the Vietnamese effective tax rate. If below 15%, declare and pay QDMTT. Notify the filing entity |
An ultimate or intermediate parent in Vietnam of an in-scope group with foreign subsidiaries | Apply the IIR to low-taxed income of foreign subsidiaries |
A group with constituent entities in Vietnam | File or designate a filer for the GIR, or notify that the GIR is filed elsewhere under exchange-of-information arrangements |
Certain entities are excluded under the rules, such as governmental entities, international organisations, non-profit organisations, and pension funds and investment funds that are ultimate parent entities.
How it is calculated: basic principles
Determine GloBE income of the Vietnamese constituent entities, starting from the financial statements used for consolidation and then adjusting as required.
Determine covered taxes, mainly CIT recognised, adjusted for deferred tax.
Effective tax rate equals covered taxes divided by GloBE income, aggregated across all constituent entities in Vietnam.
Top-up tax percentage equals 15% minus the effective tax rate.
Excess profit equals GloBE income minus the substance-based income exclusion (SBIE), which is based on payroll costs and tangible assets.
Top-up tax equals the top-up tax percentage multiplied by excess profit.
Simplified example:
Item | Amount |
GloBE income in Vietnam | VND 1,000 billion |
Covered taxes (under incentives) | VND 50 billion |
Effective tax rate | 5% |
Top-up tax percentage | 10% |
Substance-based income exclusion (assumed) | VND 200 billion |
Excess profit | VND 800 billion |
QDMTT payable in Vietnam | VND 80 billion |
The example ignores detailed adjustments under the rules. Even so, it shows that the more real employees and assets a business has in Vietnam, the lower its top-up tax.
Suggested compliance roadmap for Vietnamese subsidiaries
Confirm whether the group is in scope: compare consolidated revenue for the past 4 years with the EUR 750 million threshold.
Map constituent entities in Vietnam: subsidiaries, branches, permanent establishments and joint ventures.
Collect data early: financial statements used for consolidation, deferred tax data, payroll costs and tangible assets.
Run test calculations of the effective rate and top-up tax, including for future years as incentives change.
Coordinate with the parent: agree the filing entity, the GIR approach and shared data.
Track deadlines: notifications, QDMTT returns and GIR filing. Note any proposed changes to first-year deadlines.
Reassess incentive strategy: consider support mechanisms other than CIT incentives, such as the Investment Support Fund.
Illustrative case
Company EE is a subsidiary of a Japanese group with consolidated revenue of about EUR 3 billion. It enjoys a 10% incentive rate and CIT exemptions and reductions for a project in an economic zone. The 2024 effective tax rate of the group's Vietnamese entities was only about 4%.
After the GloBE calculations, Company EE was designated as the QDMTT filing entity in Vietnam.
The top-up tax amounts to tens of billions of dong a year.
The group took the following steps:
it set up a joint data collection process with the parent;
it recalculated the substance-based exclusion for its factory expansion plan;
it assessed access to support from the Investment Support Fund for its new project.
FAQs
Which foreign-invested businesses must pay the global minimum tax?
Vietnamese constituent entities of multinational groups with consolidated revenue of EUR 750 million or more in at least 2 of the 4 preceding years, where the effective tax rate in Vietnam is below 15%.
What is the difference between QDMTT and IIR?
QDMTT is top-up tax paid by Vietnamese entities on their own Vietnamese income. IIR is top-up tax paid by a Vietnamese parent on low-taxed income of its foreign subsidiaries.
Must a business with a CIT exemption pay QDMTT?
It may. If it belongs to an in-scope group and its Vietnamese effective rate is below 15%, it must still pay top-up tax despite its incentives.
What is the GIR?
The GloBE Information Return provides information on the group, effective tax rates and top-up tax by jurisdiction. Under Decree No. 236/2025/ND-CP, the GIR is due within 18 months after the financial year-end for the group's first year in scope, and within 15 months for subsequent years.
Legal basis
Resolution No. 107/2023/QH15 on applying additional corporate income tax under the global anti-base erosion rules.
Decree No. 236/2025/ND-CP detailing Resolution No. 107/2023/QH15.
OECD GloBE Model Rules and Administrative Guidance (for reference).
Decree No. 182/2024/ND-CP on the Investment Support Fund.
How W&A can help
The global minimum tax requires close coordination between the Vietnamese subsidiary and the overseas parent, and between consolidation accounting and local tax. W&A supports groups with:
Scope assessment and mapping of Vietnamese constituent entities.
Effective tax rate and QDMTT calculations, including projections for future years.
Filing-entity notifications, QDMTT returns and GIR filings on time, coordinated with the parent's advisers.
Reassessment of investment incentive strategy in light of the global minimum tax.
Updates on new rules and support with explanations to the tax authority.
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