Decree 236/2025/NĐ-CP, issued on August 29, 2025, provides guidance on the implementation of the global minimum tax in accordance with Resolution 107/2023/QH15. Below are the main points:
1. Taxpayers:
- Entities belonging to multinational corporations with annual revenue of 750 million euros or more for at least 2 years out of the 4 consecutive years preceding the tax financial year.
- Certain entities are exempted, including investment funds, real estate investment organizations, and other entities with specific ownership structures and operational characteristics.
2. Tax Payment: The corporate income tax supplement under the global minimum tax will be paid into the central budget.
3. Tax Period: Effective from the financial year 2024, with enforcement starting on October 15, 2025.
4. Tax Declaration Currency:
- Tax declarations must be made in the currency used in the consolidated financial reports of the parent company.
- The responsible entity must declare and pay the corporate income tax supplement in Vietnamese Dong.
- If the supplementary tax to be paid is presented in a currency other than Vietnamese Dong, the entity may choose to declare and pay the corporate income tax supplement in that currency. If the entity chooses to declare and pay in Vietnamese Dong, the conversion rate will be the average interbank exchange rate at the time of tax declaration.
5. Tax Registration Deadline:
- Entities must submit tax registration documents within 90 days after the end of the financial year.
- For corporations whose financial year 2024 ends on or before June 30, 2025, the registration deadline is 90 days from the effective date of Decree 236/2025/NĐ-CP, but no later than the deadline for tax declaration and payment applicable to that corporation.
6. Tax Filing Documentation and Deadlines:
- Tax Filing Documentation: This includes the information declaration form, the supplementary corporate income tax declaration form, the explanatory notes on discrepancies, the consolidated financial report, and the financial data report of each responsible entity, depending on whether the QDMTT (Qualified Domestic Minimum Top-up Tax) or IIR (Income Inclusion Rule) is applied.
- Filing and Payment Deadlines:
QDMTT:
- The information declaration according to the Global Minimum Tax regulations must be submitted no later than 18 months after the end of the fiscal year for the first year; and 15 months after the end of the fiscal year for subsequent years.
- The corporate income tax return, supplemented by an explanatory statement detailing the differences due to discrepancies between financial accounting standards, must be submitted no later than 12 months after the end of the fiscal year.
IIR:
The deadline for submitting the information declaration according to the Global Minimum Tax regulations, along with the corporate income tax return supplemented by an explanatory statement detailing the differences due to discrepancies between financial accounting standards, is no later than 18 months after the end of the fiscal year for the first year that multinational groups are subject to these regulations; the deadline is 15 months after the end of the fiscal year for subsequent years.
