On 29 November 2023, the Vietnamese National Assembly has approved Resolution No. 107/2023/QH15 on Global Minimum Tax (GMT) application in Vietnam in accordance with Global anti-base erosion model (GloBE) rules.

Resolution No. 107/2023/QH15 will come into effect from 1 January 2024 and GMT regulations will apply from tax year 2024.

Impacted taxpayers: constituent entity/entities (CEs) of multinational enterprise(s) (MNEs) with consolidated revenue from EUR750 million for at least 2 of 4 fiscal years preceding the current fiscal year (certain exceptions are also provided).

Application of GMT: Qualified Domestic Minimum Top-up Tax (QDMTT) and Income Inclusion Rules (IIR) were introduced and summarized as follows:

Recommendation from Grant Thornton Vietnam:

  • Review the Vietnamese CE(s) financial position and qualification for GMT application
  • Evaluate impacts from and estimate additional top-up tax arising from GMT application
  • Collaborate with headquarters and tax consultants for proper actions for GMT

Grant Thornton (Vietnam) Limited will continue to update on further development of GMT in Vietnam on our subsequent materials. Should you need to further clarification on the above matters, please do not hesitate to contact us for discussion.