Dear Clients and Partners,

The global tax landscape is undergoing its most significant transformation in decades. As we move further into 2026, the implementation of the Global Minimum Tax (GMT) under the OECD’s Pillar Two framework has transitioned from a theoretical discussion to a critical compliance reality for multinational enterprises (MNEs) operating in Vietnam.

At BLaw Vietnam, we understand that for busy executives and investors, the complexities of international tax law can be overwhelming. While the regulations are dense, the core principles that impact your bottom line can be summarized quickly. This article provides a high-level briefing of the 15% Global Minimum Tax in Vietnam, followed by a deeper dive into the technical requirements and strategic implications for your business.

The 3-Minute Briefing: What You Need to Know Right Now

If you only have three minutes, here are the essential facts:

1. The Rate: Vietnam has officially adopted a minimum effective corporate income tax (CIT) rate of 15%.
2. The Threshold: This applies to MNEs with a consolidated annual revenue of at least EUR 750 million (approximately USD 812 million) in at least two of the four preceding years.
3. The Timing: The rules became effective on January 1, 2024. However, with the issuance of Decree 236/2025/ND-CP, the administrative and filing procedures are now fully operational, with the first major compliance deadlines approaching in 2026.
4. The Mechanism: Vietnam utilizes the Qualified Domestic Minimum Top-up Tax (QDMTT). This ensures that if an MNE’s effective tax rate in Vietnam is below 15% due to traditional tax incentives, Vietnam: rather than the parent company’s home country: collects the "top-up" tax.
5. The Impact: For large-scale investors who previously enjoyed tax holidays or 5-10% preferential rates, the era of ultra-low taxation has effectively ended.

Understanding the Legal Foundation: Resolution 107 and Decree 236

To navigate this change, it is vital to understand the regulatory framework. The Vietnamese National Assembly passed Resolution No. 107/2023/QH15 in late 2023, which laid the groundwork for the GMT. This was followed by detailed implementation guidelines, most notably Decree 236/2025/ND-CP, which provides the specific roadmap for how companies must calculate their effective tax rate and fulfill their filing obligations.

For many years, Vietnam utilized aggressive tax incentives: such as "4 years of exemption and 9 years of 50% reduction": to attract Foreign Direct Investment (FDI). While these incentives remain on the books for smaller players, the GMT overrides these benefits for the world's largest companies. This shift represents Vietnam's commitment to international standards while protecting its domestic tax base from being "siphoned off" by the tax authorities of other nations.

Who Exactly Falls Within the Scope?

The scope of the GMT is strictly defined by the OECD's Global Anti-Base Erosion (GloBE) rules. Your business is likely impacted if:

• Revenue Milestone: Your global parent company reports consolidated revenue exceeding EUR 750 million.
• Presence in Vietnam: You have a constituent entity (subsidiary, branch, or permanent establishment) located in Vietnam.
• Effective Rate: Your current effective tax rate (ETR) in Vietnam, calculated after accounting for all deductions and incentives, falls below the 15% threshold.

It is a common misconception that the GMT only applies to tech giants. In reality, large manufacturing firms, automotive companies, and logistics providers operating in Vietnam's industrial zones are equally affected. If you are unsure of your standing, reviewing our guide on 7 mistakes you’re making with global minimum tax compliance can help identify potential oversight areas.

The Core Mechanisms: QDMTT and IIR

The Global Minimum Tax operates through two primary rules, both of which are now active in the Vietnamese legal system.

1. Qualified Domestic Minimum Top-up Tax (QDMTT)

This is the most critical mechanism for subsidiaries in Vietnam. If a foreign-invested enterprise in Vietnam pays an effective tax rate of only 8%, the QDMTT allows the Vietnamese government to charge an additional 7% top-up tax to reach the 15% minimum. By implementing a "Qualified" domestic tax, Vietnam ensures that this revenue stays within the country rather than allowing the parent company's home jurisdiction to claim it through their own rules.

2. Income Inclusion Rule (IIR)

The IIR applies primarily to Vietnamese-based multinationals that have subsidiaries in lower-tax jurisdictions abroad. Under the IIR, the Vietnamese parent company must pay a top-up tax in Vietnam for any of its foreign subsidiaries that are taxed at a rate lower than 15%.

Critical Deadlines for 2026

As we move through May 2026, the window for preparation is closing. Under the current Tax Administration Law, the deadline for filing the first GMT information returns and paying the top-up tax for the 2024 fiscal year is generally the end of the 15th month following the end of the fiscal year.

For companies on a standard calendar fiscal year, this means your first comprehensive GMT filing and payment are due by March 31, 2026 (which has just passed), and the next cycle of monitoring for the 2025 fiscal year is already in full swing. If you are struggling with the timing or administrative burden, it is essential to review how to avoid the biggest pitfalls in Vietnam’s July 2026 tax administration law to ensure your reporting remains accurate and timely.

Strategic Implications: Beyond the 15% Rate

The implementation of the GMT is not just about paying more tax; it is about a fundamental change in how businesses value their presence in Vietnam.

The Shift from Tax Incentives to "Investment Support"

With tax holidays becoming less effective for MNEs, the Vietnamese government is actively exploring alternative ways to maintain its competitive edge. We are seeing a shift toward:

• Direct cash grants for R&D.
• Infrastructure subsidies.
• Training and high-tech labor credits.
• Streamlined administrative procedures.

Businesses should look beyond the tax code and evaluate the total "ecosystem value" of their Vietnamese operations. This is particularly relevant when considering corporate governance; for instance, understanding Vietnam’s comply or explain rule can help your board stay aligned with the transparency standards expected of top-tier MNEs.

Transfer Pricing Risks

The GMT adds a new layer of complexity to transfer pricing. The calculation of the "Effective Tax Rate" is based on financial accounting profits, which may differ significantly from tax accounting profits. Any adjustments made during a transfer pricing audit could inadvertently push your ETR below 15% or change your top-up tax liability. We recommend consulting our latest analysis on 7 mistakes you’re making with transfer pricing in 2026 to mitigate these risks.

How Your Business Should Prepare

To successfully navigate the GMT era, BLaw Vietnam recommends the following proactive steps:

1. Impact Assessment: Conduct a detailed simulation of your ETR based on the specific formulas provided in Decree 236. Do not rely on your statutory tax rate.
2. Data Consolidation: Ensure your Vietnamese accounting team is in constant communication with the global headquarters. The GMT requires data points that are not typically found in local tax returns.
3. Review Investment Agreements: If your investment was predicated on specific tax incentives, consult with legal counsel to see if "stabilization clauses" apply or if you qualify for newly developed non-tax support measures.
4. Enhance Transparency: With the 2026 regulatory environment focusing heavily on disclosure, ensuring your beneficial owner data is current is paramount. Avoid complications by checking the 7 mistakes you’re making with beneficial owner disclosures.

Conclusion: Partnering for Compliance Excellence

The 15% Global Minimum Tax is no longer a "future problem": it is a present-day operational requirement. While the initial 3-minute explanation seems straightforward, the underlying data requirements and the interaction between local law and OECD guidelines require meticulous attention to detail.

At BLaw Vietnam, we are dedicated to helping our clients streamline their compliance processes and optimize their investment structures in this new high-transparency environment. Our team of legal and tax experts is highly qualified to guide you through the intricacies of Decree 236 and ensure your business remains both compliant and competitive.

Through the above article, we hope to have clarified the core pillars of the GMT for your organization. However, every multinational group is unique, and general advice cannot replace a tailored legal strategy.

Are you ready for the 2026 tax landscape? We invite you to reach out to our team today for a consultation. Let BLaw Vietnam be your reliable partner in navigating the complexities of the 15% Global Minimum Tax and beyond.

Contact BLaw Vietnam today to secure your business's future in the evolving Vietnamese market.