Tax & Legal updates - Key Updates from Decree 236 on Global Minimum Tax
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Key Updates from Decree 236 on Global Minimum Tax
On 29 August 2025, the Vietnamese Government issued Decree 236 to provide detailed guidance on the Global Minimum Tax (GMT), following Resolution 107. The decree takes effect on 15 October 2025 and applies from fiscal year 2024 onward.
For a recap on the GMT rules, we refer to our previous updates on Resolution 107 and GMT. GMT compliance in Vietnam is required for Constituent Entities in Vietnam of Groups with consolidated revenue from EUR 750 million and above in at least 02 of the preceding 04 years.
Key highlights
The decree details the rules for the Qualified Domestic Minimum Top-up Tax (QDMTT) and the Income Inclusion Rule (IIR), including compliance procedures and transitional measures.
- Key Deadlines: It establishes strict filing deadlines for notifications, registration forms, and tax declaration packages, with the first deadlines for FY 2024 falling in late 2025 and 2026.
- Transitional Safe Harbor determination: For fiscal years up to the end of 2026, top-up tax may be reduced to zero if an entity meets certain conditions related to its revenue, profitability, or effective tax rate.
- Penalty Waiver: Various administrative penalties for late or incorrect filings will be waived during this transitional period.
- Currency: GMT declarations can generally use the group's financial statement currency, but top-up tax must be calculated and paid in Vietnamese Dong (VND), with an option to use the foreign currency for the calculation.
Our supports
Prepare for what's next with Forvis Mazars. We cut through the complexity of new regulations, providing the strategic guidance and support to keep you compliant and ahead of the curve. If you have questions or need support with adapting to new requirements, let our experts advise you.
Please refer to the full updates in the Download section below.
Contacts
Da Nguyen Partner, Tax
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