Vietnam’s Pillar Two filing is form-led, not a standalone OECD GIR XML portal. The core compliance workstream is built around four official administrative procedures: (1) a notification of the responsible constituent entity and in-scope Vietnamese group members, (2) a special tax registration for the filing entity, (3) the qualified domestic minimum top-up tax return package (QDMTT), and (4) the income inclusion rule return package (IIR).
The GIR-equivalent information is included into Vietnam’s local filing package. For QDMTT purposes, the dossier includes both Vietnam’s own information return and, where relevant, a copy of the group GIR information covering general group data, group structure, and the ETR/top-up tax computation for Vietnamese constituent entities. If that GIR has already been filed in a jurisdiction that has an effective competent authority information-exchange agreement with Vietnam, the dossier can include Form 03/TB-ĐVHT as a notice of that foreign filing.
Members can view a Vietnam Pillar Two Filing Checklist at: Vietnam Pillar Two Filing Checklist PDF.
Vietnam’s Pillar Two package is essentially a four-step procedure:
| Procedure | Main form(s) | What it does | Deadline | Channel / result |
|---|---|---|---|---|
| Responsible entity notification | 01/TB-ĐVHT Thông báo đơn vị hợp thành chịu trách nhiệm kê khai… [notification of the responsible constituent entity and the list of in-scope constituent entities] | Identifies which Vietnamese constituent entity is responsible for filing, and lists the in-scope Vietnamese entities. | 30 days after the end of the reporting fiscal year. | Direct, postal or online on the public-service page; current GDT guidance steers taxpayers to the electronic portal. No formal decision is issued. |
| Special tax registration | 01-ĐKTĐ-ĐVHT Tờ khai đăng ký/thay đổi thông tin đăng ký thuế… [special tax registration / change form for the responsible constituent entity] | Registers the reporting entity for Pillar Two and produces the separate 10-digit tax code used to file and pay top-up tax directly. | 90 days after year-end, subject to the special FY2024 transition rule. | Online only; statutory processing time is 3 working days; result is Form 01-MST-ĐVHT. |
| QDMTT return | 01/TKTT-QDMTT, 01/TNDN-QDMTT, 01/TM, plus GIR-related attachments and financial data | Vietnam’s domestic top-up tax return package for constituent entities operating in Vietnam. | 12 months after year-end. | Online filing through the electronic tax transaction portal; no separate decision document. |
| IIR return | 01/TKTT-IIR, 01/TNDN-IIR, 01/TM, consolidated financial statements and entity-level financial data | Vietnam’s IIR filing package for the taxpayer with the IIR obligation under Resolution 107 and Decree 236. | 18 months after year-end for the first in-scope year, then 15 months. | Online filing through the electronic tax transaction portal; no separate decision document. |
The first item in the Vietnamese workflow is Form 01/TB-ĐVHT. It is the official notification that tells the tax authority which constituent entity will act as the reporting entity and which Vietnamese constituent entities are in scope for Resolution 107/2023/QH15.
The Pillar Two Decree provides that the group, or the constituent entity that the group designates, must send this notification within 30 days after the end of the reporting fiscal year. This obligation also extends to certain more specialised cases, including joint-venture structures and subgroups with a partially owned parent.
When the responsible entity or the list of in-scope entities changes, a refreshed 01/TB-ĐVHT must be re-filed no later than the filing deadline for the information return and top-up tax return for the fiscal year in which the change occurs.
From a systems angle, the tax authority’s HTKK release notes show that 01/TB-ĐVHT is not just a webform. The form supports data entry, an Excel list upload for the accompanying entity schedule, XML export, Excel export, printing, and XML download. That is a clear sign that, operationally, taxpayers should expect a local-form XML workflow behind the e-filing channel.
The second step is tax registration using Form 01-ĐKTĐ-ĐVHT. This is the Vietnam-specific Pillar Two registration that sits alongside the notification. The filing is online only, the tax office has a 3-working-day processing time, and the result is Form 01-MST-ĐVHT – effectively the tax ID notice for the filing entity.
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