Decree 236/2025: Vietnam Implements OECD Pillar Two Global Minimum Tax at 15%
Decree 236/2025/ND-CP, issued August 29, 2025, provides Vietnam's implementation of the OECD Pillar Two Global Minimum Tax (GMT) framework. Effective October 15, 2025, with retroactive application from fiscal year 2024, it requires multinational enterprises with consolidated revenue exceeding EUR 750 million to pay a minimum 15% tax rate in Vietnam. The framework includes both the Income Inclusion Rule (IIR) and Qualified Domestic Minimum Top-Up Tax (QDMTT), both recognized by the OECD as meeting transitional qualified status.
Legal Basis
Based on Resolution 107/2023/QH15 introducing additional CIT aligned with GloBE rules.
Key Features
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Scope: Multinational enterprise groups exceeding EUR 750 million in consolidated revenue during two of four preceding fiscal years.
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Tax Rate: Minimum 15% effective tax rate in each jurisdiction.
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Two Key Mechanisms:
- Income Inclusion Rule (IIR): Applied to the parent entity
- Qualified Domestic Minimum Top-Up Tax (QDMTT): Applied domestically in Vietnam
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OECD Recognition: As of August 18, 2025, both Vietnam's IIR and QDMTT frameworks are listed on the OECD Central Record as meeting transitional qualified status.
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Safe Harbor Provisions: Simplified effective tax rate thresholds — 15% (2023-2024), 16% (2025), 17% (2026).
Filing Deadlines
- QDMTT: Within 12 months after fiscal year end
- IIR: Within 15 months (18 months for first year)
- Submissions via the General Department of Taxation's electronic transaction portal