Global minimum tax Vietnam rules took effect for financial years from 2024 under Resolution 107/2023/QH15, and the implementing framework arrived with Decree 236/2025/ND-CP dated 29 August 2025, effective 15 October 2025. For large manufacturing and technology groups, the practical effect is that Vietnamese tax incentives no longer deliver the after-tax result they were designed to deliver.
This guide sets out the six impacts we are asked about most, and what groups can do in response.
Global Minimum Tax Vietnam: Who Is In Scope
The regime applies to constituent entities of multinational groups whose ultimate parent had consolidated revenue of at least EUR 750 million in at least two of the four financial years immediately preceding the financial year concerned.
The test is applied at group level, so a modest Vietnamese subsidiary of a large group is in scope while a substantial standalone Vietnamese business is not. Groups sitting near the threshold should monitor it annually rather than assuming a prior-year conclusion still holds.
Global Minimum Tax Vietnam: The Qualified Domestic Minimum Top-Up Tax
Vietnam applies a qualified domestic minimum top-up tax. Where the effective tax rate of the group’s constituent entities in Vietnam, calculated on a jurisdictional basis, falls below fifteen per cent, Vietnam collects the difference itself rather than allowing another jurisdiction to collect it.
This is the central point for incentive holders. A company enjoying a four-year exemption and nine years at half rate may have an effective rate far below fifteen per cent, and the global minimum tax Vietnam mechanism recovers the shortfall domestically. The incentive is not withdrawn; its economic value is.
Global Minimum Tax Vietnam: The Income Inclusion Rule
Vietnam also applies an income inclusion rule, under which a Vietnamese ultimate or intermediate parent entity is liable for top-up tax in respect of low-taxed constituent entities abroad.
This matters for Vietnamese groups that have invested offshore, a growing population given the outbound framework in Decree 103/2026/ND-CP. Vietnamese-headquartered groups above the revenue threshold now need jurisdictional effective tax rate calculations for their foreign subsidiaries. See our note on outbound investment by FDI enterprises.
Global Minimum Tax Vietnam: Calculating the Effective Tax Rate
The effective rate is computed on a jurisdictional basis by aggregating covered taxes and adjusted qualifying income of all constituent entities in Vietnam. It is not a company-by-company calculation, so a profitable entity paying the standard rate can offset an incentivised entity in the same group.
A substance-based income exclusion reduces the profit subject to top-up tax by reference to payroll and tangible asset carrying value in Vietnam. Capital-intensive manufacturers with large workforces therefore face a smaller top-up than asset-light structures with the same accounting profit.
Global Minimum Tax Vietnam: Filing and Payment
Decree 236/2025/ND-CP sets out the declaration, information return and payment mechanics, with filings made through the tax authority’s electronic portal. The deadlines run from the end of the financial year and are materially later than ordinary corporate income tax finalisation, which lulls groups into leaving the work too late.
The data required comes from consolidated group reporting rather than Vietnamese statutory accounts, so the finance function that produces it is usually at headquarters rather than in Vietnam. Assigning ownership early is the practical lesson.
Global Minimum Tax Vietnam: What Groups Can Do
Cash incentives and support measures that are not creditable against the effective tax rate calculation preserve value in a way that rate-based incentives no longer do. Vietnam has been developing investment support mechanisms with this in mind, and negotiations for large projects increasingly focus on them.
Groups should also revisit where profit is booked, since a Vietnamese effective rate below fifteen per cent no longer produces a group benefit. Restructuring the intercompany model to reflect where value is actually created is often the cleanest response. Our guides to restructuring and tax and transfer pricing audits examine the options.
Frequently Asked Questions
Are existing tax incentives cancelled?
No. They remain legally in force, but the top-up tax recovers the difference between the effective rate and fifteen per cent for in-scope groups.
Does the regime apply to Vietnamese domestic groups?
Only where they are part of a multinational group meeting the revenue threshold.
How is the EUR threshold converted?
By reference to the consolidated financial statements of the ultimate parent, with conversion applied consistently across the testing years.
Does the substance carve-out help labour-intensive manufacturers?
Yes. The exclusion is calculated by reference to payroll and tangible assets, which favours manufacturing over asset-light operations.
Model Your Exposure
IVLF Advisors models jurisdictional effective tax rates, assesses the top-up exposure, reviews incentive value against the new baseline and advises on restructuring and support measures. See also our tax practice and guidance from the Ministry of Finance. Contact our team.
This article is provided for general information only and does not constitute legal advice for any specific case. Regulations may change – please consult a qualified professional before acting. Should further analysis be required, please contact one of our lawyers below.
