Vietnam Issues Decision 3563/QD-BTC 2025 on Administrative Procedures for the Minimum Tax

On October 21, 2025, Vietnam released Decision 3563/QD-BTC 2025 on the Administrative Procedures for the Minimum Tax. This includes the final forms to be submitted for notification, registration and returns.

The forms are also published as Administrative Procedures on Vietnams E-Filing  portal and split into 4 filing Pillar 2 Filing Packages:

-Code 1.014405 – Notification of CEs; 

-Code 1.014406 – Registration;

-Code 1.014407 – QDMTT filing; and

-Code 1.014408 – IIR filing.

Code 1.014405 – Notification of CEs

Article 6(3) of the Minimum Tax Resolution (Article 14(1) of the Decree) provides that if an MNE group has more than one constituent entity in Vietnam, the UPE or a constituent entity in Vietnam is required to submit a notification to designate the filing constituent entity within 30 days from the end of the reporting fiscal year using Form No. 01/TB-ĐVHT.

Code 1.014405 provides the Form 01/TB-ĐVHT. This can be filed electronically, directly with the Tax Authority or via post. 

Code 1.014406 – Registration

Article 15(6) of the Minimum Tax Decree provides that MNE groups with Constituent Entities in Vietnam are required to register within 90 days from the end of the reporting fiscal year using form No. 01-DKTD-DVHT. This is extended to 90 days from the effective date of the Decree (the effective date is October 15, 2025) for groups with a FY 2024 ending on or before 30 June 2025, but not later than the deadline for the tax declaration and payment applicable to that entity.

Code 1.014406 provides for the Form No. 01-DKTD-DVHT. This must be filed electronically via the e-filing portal. 

Code 1.014407 – QDMTT filing

Article 6(1) of the Minimum Tax Resolution and Article 16 of the Decree also require the submission of a QDMTT Tax Return. The deadline for filing a domestic top-up tax return is 12 months after the end of the fiscal year. An additional QDMTT Information Declaration is also required to be submitted.

Code 1.014407 provides for the QDMTT filing obligation and includes: 

-An information declaration form (Form No. 01/TKTT-QDMTT)

-Double filing relief notification (Form No. 03/TB-DVHT)

-A supplementary corporate income tax declaration form (Form No. 01/TNDN-QDMTT)

-An explanatory statement explaining any difference in the financial accounting standard used (Form No. 01/TM)

-The GIR (unless this is not required)

-A report on the financial data of each constituent entity used for the purpose of preparing the Consolidated Financial Statements of the UPE.

These are all filed electronically via the e-filing portal. 

Code 1.014408 – IIR filing

Article 6(2) of the Minimum Tax Resolution and Article 16 of the Decree also require the submission of a Top-Up Tax Return for IIR purposes. The deadline for filing an IIR Top-Up Tax Return for the IIR is 15 months after the end of the fiscal year (18 months in the transition year).  

Code 1.014408 provides that the IIR Top-up Tax filing includes:

-An information declaration form (Form No. 01/TKTT-IIR)

-A Supplementary corporate income tax declaration form (Form No. 01/TNDN-IIR)

-An explanatory statement explaining any difference in the financial accounting standard used (Form No. 01/TM)

-Consolidated financial statements of the UPE

-A report on the financial data of each constituent entity used for the purpose of preparing the Consolidated Financial Statements of the UPE.

These are all filed electronically via the e-filing portal.