In short: Vietnam applies a 15% global minimum tax from 1 January 2024 under Resolution 107/2023/QH15. Multinational groups with consolidated revenue of EUR 750 million or more whose effective tax rate in Vietnam is below 15% must pay a top-up corporate income tax. This reduces the real economic value of traditional tax incentives many FDI enterprises currently enjoy.
1. What is the global minimum tax?
The Global Minimum Tax (GMT) is the international tax framework developed by the Inclusive Framework on Base Erosion and Profit Shifting, of which Vietnam is a member. Its goal: ensure large multinational groups bear a minimum 15% effective tax rate in each jurisdiction where they operate, curbing profit shifting to low-tax jurisdictions.
Vietnam implemented the framework through Resolution 107/2023/QH15 on the application of top-up corporate income tax under the global anti-base-erosion rules, effective 1 January 2024, detailed in Decree 19/2024/ND-CP.
2. Who is in scope?
Under Resolution 107/2023/QH15, the GMT applies to multinational groups with consolidated revenue of EUR 750 million or more in at least two of the four preceding fiscal years, with constituent entities conducting production or business activities in Vietnam.
Not every FDI enterprise is affected — only large groups meeting the global revenue threshold must compute and file. Smaller FDI enterprises and groups below the threshold continue under ordinary corporate income tax rules.
3. Two mechanisms: QDMTT and IIR
Resolution 107/2023 establishes two top-up tax mechanisms:
QDMTT — Qualified Domestic Minimum Top-up Tax: applies to constituent entities in Vietnam with an effective tax rate below 15%. The top-up tax equals (15% − effective rate) × the top-up tax base, plus adjustments. Crucially, this tax is collected in Vietnam — rather than letting the parent company’s jurisdiction collect it, Vietnam keeps the revenue.
IIR — Income Inclusion Rule: applies where the ultimate parent entity sits in a jurisdiction that has implemented the IIR, collecting top-up tax attributable to low-taxed constituent entities.
4. Filing and payment deadlines
Under Article 6 of Resolution 107/2023/QH15:
- QDMTT: the GloBE Information Return (GIR), the top-up tax return with an explanatory statement on accounting-standard differences, and the tax payment are due no later than 12 months after the fiscal year-end.
- IIR: no later than 18 months after fiscal year-end for the first year in scope, and 15 months for subsequent years.
Enterprises need GloBE-ready accounting systems — a significant challenge given the short preparation window.
5. Direct impact on FDI enterprises enjoying incentives
This is investors’ top concern. Many FDI enterprises in Vietnam enjoy corporate income tax incentives: preferential rates of 10% or 5%, tax holidays and reductions. Under the GMT:
- If the entity’s effective tax rate (ETR) in Vietnam is below 15%, it must pay top-up tax to reach 15%.
- Incentives remain legally available, but their real economic benefit shrinks — the difference is effectively “clawed back” through the top-up tax.
According to figures released by the Deputy Director of the Department of Taxation at a seminar on 28 September 2026: of roughly 45,000 operating FDI projects, only about 1,500 fall within GMT filing scope, and fewer than 200 enterprises actually incurred top-up tax liability. In 2025, Vietnam collected approximately VND 16.5 trillion from the global minimum tax.
6. Replacement policies: from tax incentives to performance-based support
Recognizing that traditional tax incentives lose force under the GMT, Vietnam is shifting its FDI attraction strategy:
- The Investment Support Fund (established under Decree 182/2024/ND-CP of 31 December 2024): supports high-tech enterprises and large-scale projects affected by the GMT, through cost-based support (infrastructure, workforce training, R&D) rather than tax cuts.
- Draft amendments to the Law on Investment under preparation add four new forms of investment support: supply-chain development; production, product and technology improvement; initial investment and fixed-asset investment; and cooperation between enterprises and universities, vocational institutions and science-technology organizations. The overall direction: post-investment, performance-based incentives tied to actual project outcomes.
7. What should FDI enterprises do?
- Check scope: compare the group’s consolidated revenue against the EUR 750 million threshold.
- Compute the Vietnamese ETR: determine whether top-up tax arises.
- Build GloBE-ready accounting: ensure data for income and rate computations meets GMT standards; watch for differences between Vietnamese accounting standards and international ones.
- Reassess incentive strategy: evaluate the real post-GMT value of current tax incentives; explore replacement support (Investment Support Fund, R&D and training support).
- Meet filing deadlines: 12 months for QDMTT, 18/15 months for IIR after fiscal year-end.
FAQ
Q: Must every FDI enterprise pay the global minimum tax?
A: No. Only multinational groups with consolidated revenue of EUR 750 million or more (in at least 2 of 4 fiscal years) fall in filing scope, and only entities with an effective rate below 15% incur top-up tax.
Q: Are current tax incentives lost?
A: Incentives still apply by law. But if the post-incentive effective rate is below 15%, top-up tax brings it to 15% — narrowing the incentive’s economic value accordingly.
Q: Where is the top-up tax paid?
A: Under QDMTT, in Vietnam. Under the IIR, it may be collected in the parent company’s jurisdiction if that jurisdiction has implemented the IIR.
Q: What does the Investment Support Fund cover?
A: Established under Decree 182/2024/ND-CP to support high-tech enterprises and large projects affected by the GMT. Specific eligibility and support levels are set by the Government — enterprises should consult the competent authorities.
Sources
- Resolution 107/2023/QH15 on top-up corporate income tax under the global anti-base-erosion rules (effective 1 January 2024)
- Decree 19/2024/ND-CP guiding Resolution 107/2023/QH15
- Decree 182/2024/ND-CP on the establishment, management and use of the Investment Support Fund (31 December 2024)
- Figures: statement by the Deputy Director of the Department of Taxation at the 28 September 2026 seminar (press reports)
This article is for general information only and does not constitute legal advice for any specific case. Content is pending review by the QA Council (FLAW AI Legal Council).