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Tax Alert | September 2025 | Decree guiding the application of Global Minimum Tax policy in Vietnam
This alert provides a summary of the key provisions on the top-up corporate income tax under the GloBE rules, as stipulated in Resolution No. 107/2023/QH15 and Decree 236/2025/ND-CP.
On 29 August 2025, the Government officially issued Decree 236/2025/ND-CP providing details for a number of articles of the National Assembly's Resolution No. 107/2023/QH15 dated 29 November 2023 regarding the application of the top-up corporate Income tax in accordance with the Global Anti-Base Erosion (GloBE) rules.
This Decree takes effect from 15 October 2025 and applies from the 2024 financial year (FY). The 2024 FY is defined as a FY beginning on or after 1 January 2024. In cases where a constituent entity (CE) applies the qualified domestic minimum top-up tax (QDMTT) and determines 2024 FY according to its ultimate parent entity (UPE)’s FY where the starting day of the FY is in December 2023, it will be considered the 2024 FY as stipulated in this Decree.
This Tax Alert provides a summary of the key provisions on the top-up corporate income tax under the GloBE rules, as stipulated in Resolution No. 107/2023/QH15 and Decree 236/2025/ND-CP.
For detailed information, please refer to the attached documents.