The Decree outlines Vietnam’s Pillar 2 global minimum tax rules for MNEs, including IIR and QDMTT, specifying notification, registration, and reporting deadlines.
Vietnam’s government announced that it has issued Decree No. 236/2025/ND-CP, detailing the implementation of Pillar Two global minimum tax rules on 29 August 2025. These rules include compliance obligations and procedures for MNE groups, covering both the income inclusion rule (IIR) and the qualified domestic minimum top-up tax (QDMTT).
The decree also includes the compliance obligations and deadlines for the new rules.
These include notification of the designated constituent entity and in-scope entities must be submitted within 30 days after the UPE’s fiscal year end.
Tax registration must be submitted within 90 days after the UPE’s fiscal year-end. For fiscal years ending by 30 June 2025, the deadline is extended to 90 days after the decree enters into force.
Annual top-up tax returns and GloBE Information Returns must be submitted within deadlines that vary by QDMTT or IIR and fiscal year, ranging from 12 to 18 months for 2024 and 15 months for 2025 and subsequent years.
Transitional penalty relief applies with no or reduced penalties for certain late submissions and compliance infractions for fiscal years beginning on or before 31 December 2026.
