GloBE Country Guide: Vietnam

Summary

Status	Enacted Law
Law	On August 29, 2025, Vietnam issued Decree 236/2025/ND-CP providing for the detailed provisions for the application of the Pillar 2 Global Minimum Tax rules in Vietnam. Resolution No: 107/2023/QH15 of December 21, 2023 On November 12, 2024, the Vietnamese Ministry of Finance released a draft Decree on the implementation of Resolution No. 107/2023/QH15 on the Global Minimum Tax. The draft decree provides for the detailed application of the GloBE rules in Vietnam.
Effective Date	Accounting periods beginning on or after January 1, 2024
IIR	Yes (2024)
UTPR	No
QDMTT	Yes (2024)
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour, QDMTT Safe Harbour and the Simplified Calculations Safe Harbour for NMCEs

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

Access the GloBE Country Guide Below

Sign into your account to access this analysis

Not a Subscriber?

If you haven’t got a subscription you can sign up below

Already a Subscriber?

Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

Cookie	Duration	Description
cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Poland Issues Draft Pillar 2 Notifications and Top-Up Tax Returns

Vietnam Issues its Pillar 2 Decree

Portugal Issues its Pillar 2 Registration Form

Czech Republic Gazettes Act No. 316/2025 to Amend its Minimum Tax Act