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Last amendment: Decree 236/2025/NĐ-CP issued by the Government to provide detailed subordinate computational rules for Resolution 107's top-up-tax regime, enabling MNEs to calculate and file the QDMTT for fiscal year 2024. Effective 15 October 2025. on 2025-08-29.
Resolution 107/2023/QH15, passed by the 6th session of the 15th National Assembly on 29 November 2023 and effective from 1 January 2024, is Vietnam's primary statutory instrument implementing the OECD/G20 Inclusive Framework Pillar Two GloBE (Global Anti-Base Erosion) model rules. It inserts two top-up-tax charges into Vietnamese corporate income tax law:
1. QDMTT (Qualified Domestic Minimum Top-up Tax): Collected by Vietnam on the under-taxed income of constituent entities resident in Vietnam whose ETR falls below 15%. Because it is OECD-qualified, foreign IIR charges by the parent jurisdiction must credit the Vietnamese QDMTT, effectively allowing Vietnam to capture top-up revenue that would otherwise flow to the parent-state treasury. 2. IIR (Income Inclusion Rule): Applied by Vietnamese parent entities on the low-taxed income of their foreign constituent entities, subject to the same 15% minimum ETR and EUR 750M consolidated revenue threshold.
The in-scope revenue threshold (EUR 750 million in at least two of the four preceding fiscal years) mirrors the OECD GloBE model rules exactly. The law applies from fiscal year 2024, meaning the first actual top-up-tax liability accrues in 2024 with compliance filings due in 2025 once the subordinate decree (Decree 236/2025/NĐ-CP) took effect on 15 October 2025.
Vietnam's adoption is structurally significant for two reasons. First, it is the first major South-East Asian low-effective-tax hub to adopt GloBE by statute — confirming that the traditional investment-incentive architecture (tax holidays, enterprise zones with effective CIT rates of 5-10%) that underpinned Vietnam's FDI boom since the 1990s will be superseded by the 15% floor for all large-group in-scope investors. Second, Vietnam's choice to enact a QDMTT allows it to retain the top-up revenue domestically rather than ceding it to headquarter-country IIRs (primarily the EU, South Korea, the UK, and Canada — all of which now have binding Pillar Two domestic legislation).
The primary in-scope population is the large base of globally integrated manufacturing MNEs that use Vietnam as an export-oriented production hub:
global handset output, roughly USD 65-70bn annual export value)
Viettel (telco), Hoa Phat Group (steel), Vinamilk — these are affected as outbound IIR payers if their foreign subsidiaries are under-taxed
for high-tech projects) are effectively capped at 15% for in-scope MNEs — the top-up tax neutralises the below-15% incentive unless redesigned as Qualified Refundable Tax Credits (QRTCs)
to retain FDI attractiveness post-Pillar Two
policy pressure to enact equivalent QDMTT measures or lose top-up revenue to headquarter-country IIRs
will face domestic top-up charges — relevant for Vingroup's overseas ventures
attractive for FDI targeting below-threshold MNE groups
publicly announced as of Aug 2025