The global minimum tax has turned Southeast Asia’s tax incentive contest into a new game: when every large group must pay at least 15 percent somewhere, the question is no longer which country offers the lowest rate, but which country collects the top-up and what it gives investors back outside the tax system. Vietnam answers with a pair of instruments — collecting the domestic top-up and creating a cash support fund — while each ASEAN peer answers differently. This article compares those responses and their direct consequences for a covered group’s location decision.
Short answer
Vietnam applies a domestic minimum top-up tax under Resolution 107/2023/QH15 and Decree 236/2025/ND-CP, effective from 15 October 2025, with a 15 percent floor for groups whose consolidated revenue reaches the global threshold of 750 million euros. Vietnam’s distinctive move is Decree 182/2024/ND-CP establishing an Investment Support Fund that uses the budget to co-fund training, research and development and fixed asset costs for high-tech companies and those subject to the global minimum tax. Singapore and Malaysia have likewise enacted domestic top-up mechanisms, while Thailand and Indonesia are at earlier completion stages; competition is therefore shifting from tax rates to the quality of non-tax support and licensing speed.
Vietnam’s mechanism: collect the top-up at home, support back in cash
The logic of a qualified domestic minimum top-up tax, or QDMTT, is direct: if a Vietnamese project enjoys incentives that pull its effective rate below 15 percent, the difference will be collected somewhere — either in Vietnam under the domestic mechanism or in the parent company’s country under the income inclusion rule. Resolution 107/2023/QH15 chose collection in Vietnam, and Decree 236/2025/ND-CP details the filing and payment of the top-up with effect from 15 October 2025. In parallel, the Investment Support Fund under Decree 182/2024/ND-CP lets the state co-fund eligible costs of high-tech enterprises, research and development centres and companies within the global minimum tax scope. Economically, investors no longer keep sub-15-percent tax benefits, but can receive support tied to real costs; legally, the incentives in the Corporate Income Tax Law 67/2025/QH15 remain fully valuable for projects outside the minimum tax scope, which is most mid-sized companies.
| Country | Domestic top-up mechanism | Standout offset tool |
|---|---|---|
| Vietnam | Applies under Resolution 107/2023/QH15 and Decree 236/2025/ND-CP, effective 15 October 2025 | Investment Support Fund under Decree 182/2024/ND-CP, cash support by cost item |
| Singapore | Domestic top-up enacted for large groups under the global framework | Grant and refundable-credit schemes for high-value activities |
| Malaysia | Roadmap announced for minimum tax under the global framework | Project-based incentives and priority sector support via its promotion agency |
| Thailand | Domestic top-up mechanism being finalised | Promotion agency designing support packages to replace tax holidays |
| Indonesia | Framework at an early completion stage | Pioneer-sector tax holidays continue for out-of-scope projects |
ASEAN responses: one tax floor, four offset styles
Singapore moved fastest legislatively and uses its existing grant ecosystem for research, innovation and regional headquarters to retain groups, accepting that its traditional tax edge narrows. Malaysia ties its response to new industrial policy, prioritising high-value sectors and using its investment promotion agency as the negotiating point for project packages. Thailand, which used promotion-agency tax holidays as its main weapon for decades, is hit most directly and is designing non-tax support packages to replace the value the 15 percent floor erodes. Indonesia is moving more slowly, continuing pioneer-sector tax holidays as its competitive tool for projects below the global revenue threshold. The common picture: no country has stopped competing; they have simply switched weapons from tax rates to cash, infrastructure and licensing speed.
Consequences for a large group’s location decision
For a covered group, the location comparison model must be rewritten at three points. First, tax incentives below the floor are no longer a cash advantage in any ASEAN country operating a top-up; the remaining value sits in non-tax support, which differs by conditions, payment timing and legal certainty. Second, minimum tax filing creates a new global compliance layer: country-by-country data must reconcile between subsidiary and parent, so the quality of tax advice where the project sits becomes a location criterion. Third, for out-of-scope projects — groups below the consolidated revenue threshold — Vietnam’s traditional incentives, such as 10 percent for 15 years with four years exempt and nine years at half rate, keep their full cash value, leaving Vietnam highly competitive for mid-sized companies and satellite suppliers.
Risks and practical notes
First, support from the Investment Support Fund is not an automatic entitlement: the company must be an eligible subject, costs must be eligible and the file must pass appraisal; support should not be booked as certain in a financial model before an approval document exists. Second, the application timeline and filing guidance of Decree 236/2025/ND-CP need close tracking in the first periods, because top-up filing practice is new in every ASEAN country. Third, multi-tier group structures need a full review: minimum tax is computed on a jurisdictional consolidated basis, and a legacy tax-optimised structure can create unexpected differences. Fourth, the investment guarantee in the Investment Law 143/2025/QH15 does not exempt companies from the global minimum tax, which is an international commitment separately legislated through Resolution 107/2023/QH15.
Action checklist
- Determine whether the group’s consolidated revenue reaches the global minimum tax threshold.
- Model the effective rate after the top-up under Decree 236/2025/ND-CP for the Vietnamese project.
- Match each planned cost item against Investment Support Fund eligibility under Decree 182/2024/ND-CP.
- Compare ASEAN non-tax support packages by payment timing and legal certainty, not by programme names.
- Keep the traditional incentive analysis intact if the project is outside the minimum tax scope.
- Set up consistent filing data processes between the Vietnamese company and the parent from the first period.
Frequently asked questions
How are ASEAN countries responding to the global minimum tax?
All are moving the same way: enacting or finalising a domestic top-up mechanism to collect the sub-15-percent difference at home instead of letting the parent’s country collect it. They differ in speed and offset tools: Singapore is fast and uses existing grants, Malaysia ties support to industrial policy, Thailand is redesigning its promotion agency packages, Indonesia is slower and still leans on tax holidays for out-of-scope projects, and Vietnam pairs Decree 236/2025/ND-CP with a cash Investment Support Fund.
Which country has the best offset policy for investors?
There is no single answer for every project because offsets are designed by cost type. A company spending heavily on training, research and fixed assets in Vietnam can benefit visibly from the Investment Support Fund under Decree 182/2024/ND-CP. A group placing a regional headquarters and research centre often finds Singapore’s packages a better fit. The correct scoring lists the cost items each country will support, with conditions and payment timing, rather than comparing programme names.
How does this affect my location decision?
If your group is in scope, remove sub-floor tax incentives from the comparison table and re-score on non-tax support, infrastructure, talent and procedure speed — the country ranking can change completely versus the old table. If your group is out of scope, the minimum tax does not touch your project and Vietnam’s traditional incentives, such as 10 percent for 15 years, remain a full cash advantage. Identifying which group you belong to is the first analytical step, before any other comparison.
FLAT Law Firm accompanies investors
FLAT Law Firm helps groups within the global minimum tax scope model the Vietnamese impact: top-up duties under Resolution 107/2023/QH15 and Decree 236/2025/ND-CP, support eligibility under the Investment Support Fund in Decree 182/2024/ND-CP, and the traditional incentives that retain value under the Corporate Income Tax Law 67/2025/QH15. Send us your group structure and project cost plan to receive a two-layer tax and support analysis before you lock in a location.
This article has been quality-reviewed by the FLAW AI Legal Council
