Global Minimum Tax: What Businesses Should Prepare After Decree 236/2025/ND-CP

On August 29, 2025, the Government officially issued Decree 236/2025/ND-CP, providing detailed guidance on the implementation of Resolution 107/2023/QH15 of the National Assembly regarding the Global Minimum Tax (GMT). This marks a significant step in aligning Vietnam with international tax practices, while also creating new challenges for multinational corporations operating in the country.

Who Will Be Affected?

The Decree applies to constituent entities of multinational enterprises (MNEs) with consolidated revenues of EUR 750 million or more in at least two of the four preceding fiscal years.

• Constituent entities in Vietnam will be subject to the Qualified Domestic Minimum Top-up Tax (QDMTT).
• Ultimate parent entities, partially owned parent entities, or intermediate parent entities in Vietnam may also be subject to the Income Inclusion Rule (IIR) if they have low-taxed entities abroad, unless the top-up tax has already been paid in a jurisdiction applying the GMT priority rules.

This means MNEs must not only review their structure in Vietnam but also consider the impact from subsidiaries across other jurisdictions.

Registration, Filing, and Payment – Key Deadlines

The Decree outlines detailed procedures:

• Registration: MNEs must notify the tax authority of the reporting entity within 30 days after the fiscal year ends. Initial registration must be completed within 90 days, with a special timeline for the fiscal year 2024.
• Filing and Payment:
  • QDMTT: within 12 months after the end of the fiscal year.
  • IIR: within 18 months for the first fiscal year and 15 months for subsequent years.

Tax filings will require comprehensive documentation, including information returns, top-up tax returns, reconciliations, and relevant financial statements.

Insights from Baker Tilly A&C Experts

According to Baker Tilly A&C’s experts, compliance with the Global Minimum Tax will be a complex journey for many MNEs, given the significant volume of cross-border data, strict deadlines, and high transparency requirements.

“The implementation of the Global Minimum Tax will fundamentally change how multinational corporations manage their tax and financial structures. Businesses need to quickly determine their scope of applicability, establish robust global data collection processes, and adhere strictly to filing deadlines. At this critical juncture, partnering with professional advisors will be crucial to ensure compliance and maximize benefits,” said a Baker Tilly A&C representative.

Recommendations for Businesses

Baker Tilly A&C highlights three essential actions:

1. Review group structure to identify affected entities and tax obligations.
2. Invest in global financial data systems to meet rigorous reporting requirements.
3. Stay updated and seek expert advice to ensure effective compliance.

Conclusion

Decree 236/2025/ND-CP signals a new era of international tax governance in Vietnam. The Global Minimum Tax presents both challenges in compliance and opportunities to strengthen corporate governance and long-term resilience.

With extensive expertise in international tax advisory, Baker Tilly A&C is committed to supporting businesses in navigating this transformation—helping clients not only comply but also build stronger foundations for future growth.