Vietnam issues Decree on implementation of Global Minimum Tax rules under OECD Pillar Two Framework
04 September, 2025
On 29 August, the Government issued Decree 236/2025/NĐ-CP, setting out top-up tax regulations pursuant to Resolution 107/2023/QH15. This long-anticipated decree establishes the legal framework for applying the Global Anti-Base Erosion (GloBE) rules under the OECD Pillar Two framework in Vietnam, including the Qualified Domestic Minimum Top-up Tax (QDMTT) and the Income Inclusion Rule (IIR).
The decree arrives at a pivotal moment, with effective date of 15 October 2025, enabling multinational enterprises to prepare for their first top-up tax filings for the 2024 fiscal year.
