Vietnam has applied the supplementary corporate income tax under the global anti-base erosion rules from the 2024 tax year under Resolution 107/2023/QH15, with detailed guidance in Decree 236/2025/ND-CP (issued 29 August 2025, effective 15 October 2025). It covers Vietnamese constituent entities of multinational groups with consolidated global revenue of at least EUR 750 million in at least 2 of the 4 preceding years. According to the Ministry of Finance, as of 10 July 2026, 1,654 groups had filed QDMTT returns and 23 groups had filed under the IIR, with about VND 16,000 billion of top-up tax paid.
Key filing deadlines (counted from the ultimate parent’s fiscal year-end)
| Deadline | Filing |
|---|---|
| + 30 days | List of constituent entities and notice of the designated filing entity (Form 01/TB-ĐVHT) |
| + 90 days | Tax registration (Form 01-ĐKTĐ-ĐVHT) |
| + 12 months | Top-up CIT returns (QDMTT, IIR) and explanation of accounting standard differences |
| + 15 months (18 in the first year) | GloBE Information Return (GIR) |
7 common errors and difficulties
- Miscounting deadlines: using the Vietnamese entity’s fiscal year instead of the ultimate parent’s to count the 30-day, 90-day and 12-month deadlines.
- Misapplying the EUR 750 million threshold: the test is “2 of the 4 preceding years”, not just the current year; currency translation and consolidation scope are also frequently mishandled.
- No designated filing entity: groups with several Vietnamese entities fail to notify which one files – a problem highlighted by the tax authority; the draft amendment would let the authority designate one.
- Misusing the transitional CbCR safe harbour: it requires a qualified country-by-country report and one of the tests (revenue under EUR 10 million and profit under EUR 1 million; a simplified ETR of at least 16% for 2025 and 17% for 2026; or the routine profits test). It does not apply to fiscal years ending after 30 June 2028.
- Incomplete GloBE income adjustments: errors when moving from VAS figures to the consolidated accounting standard, missing explanations of differences (Form 01/TM), and incorrect treatment of deferred tax and tax incentives.
- Miscalculating the substance-based income exclusion (SBIE): omitting or misstating eligible payroll costs and tangible asset values, which inflates top-up tax.
- Late data from the parent: consolidating overseas figures is often late or out of sync with Vietnamese deadlines; the draft amendment proposes extending the first-year deadline to up to 18 months.
Penalties and upcoming changes
Decree 236/2025/ND-CP waives administrative penalties for notices, registrations and returns filed up to 90 days late, or errors that do not reduce tax payable – this relief does not apply where an error results in underpaid tax. The draft amendment also adds the “Side-by-Side” mechanism: IIR top-up tax is zero where the ultimate parent is in a jurisdiction whose regime the OECD has recognised (currently only the United States), while Vietnam keeps its right to collect QDMTT.
How APA supports FDI enterprises
APA reviews the constituent entity list, builds the filing calendar from the parent’s fiscal year, and reconciles GloBE figures with audited financial statements and transfer pricing documentation under Decree 255/2026/ND-CP, reducing the risk of errors before filing.
Legal references
- National Assembly 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 the additional corporate income tax (global minimum tax)
- Decree No. 255/2026/ND-CP – on tax administration for enterprises with related-party transactions
- Law on Tax Administration No. 108/2025/QH15
