How Vietnam aligns its financial standards with global minimum tax rules

Effective 15 October 2025, the GMT will be incorporated into Vietnam’s corporate income tax (CIT) regime through two core mechanisms: the income inclusion rule (IIR) and the qualified domestic minimum top-up tax (QDMTT).

GMT application to Vietnam’s CIT regime

MNE groups with consolidated revenue of at least EUR 750 million in at least two of the four years prior to the testing year are subject to Vietnam’s GMT rules. The regime applies from the 2024 fiscal year.

To cushion potential shocks to corporate financial planning, Decree 236 introduces transitional provisions and Country-by-Country Reporting (CbCR) safe harbours for qualifying MNEs that meet certain thresholds, such as a de minimis revenue and profit limit, a simplified effective tax rate of 15% for FY2023–2024, 16% for FY2025, and 17% for FY2026, or a net loss position.

The QDMTT in Vietnam may be zero for early-stage MNE groups meeting limits on countries and assets. An MNE's IIR top-up tax is also zero if the QDMTT qualifies for the safe harbour, according to the Inclusive Framework on BEPS.

Beyond the transitional period, permanent safe harbours continue to apply under the routine profits, de minimis, or effective tax rate tests. Administrative penalty relief is also available during the initial phase to support smoother compliance.

To support businesses in complying with the GMT regulations, the regime is administered exclusively by the Sub-Department of Taxation for Large Enterprises under the Tax Department, rather than by the provincial tax departments currently managing businesses.

How Decree 236 alters Vietnam’s financial accounting standards

Decree 236 aligns Vietnam’s accounting framework with the QDMTT and IIR. Accounting standards must follow those used to prepare the ultimate parent entity’s (UPE) consolidated financial statements. For exchange rate determination, if the UPE’s financial statements are in VND, the average December rate of the previous fiscal year from the State Bank of Vietnam applies. If in another currency, the European Central Bank’s December rate is used, or, if unavailable, the UPE’s national central bank rate.

Takeaways for multinational corporations

By issuing Decree 236, Vietnam has aligned its tax framework with OECD standards, signalling a commitment to global transparency and equitable taxation. Businesses should stay proactive in updating and interpreting the new regulation, consult professional advisors to assess their potential impact on specific business models, and continuously strengthen internal controls to minimise compliance and tax risks.

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Ms Pham Thi Hoai Thu (Mia Pham) brings over eleven years of expertise in audit, accounting, financial reporting, and tax advisory across various industries. She is Deputy Director, Corporate Accounting Service at Dezan Shira & Associates, Vietnam. Her experience also includes payroll and personal income tax services for both local Vietnamese staff and expatriates working in Vietnam.