Vietnam_ QDMTT

 It appears you're asking about the implementation of global minimum tax rules in Vietnam, specifically relating to what's formally known as the Qualified Domestic Minimum Top-up Tax (QDMTT). This is part of the OECD/G20 Pillar Two framework aimed at ensuring large multinational enterprises (MNEs) pay a minimum level of tax.

Here's what you need to know about the QDMTT in Vietnam:

  1. Implementation: Yes, Vietnam has implemented rules for a global minimum tax, including a QDMTT.
  2. Legislation: This was done through Resolution No. 107/2023/QH15, passed by the National Assembly on November 29, 2023.
  3. Effective Date: The rules, including the QDMTT and the Income Inclusion Rule (IIR), took effect from January 1, 2024, and apply starting from the 2024 fiscal year.
  4. Purpose: The QDMTT ensures that MNEs operating in Vietnam pay an effective tax rate (ETR) of at least 15% on their profits generated within Vietnam. It allows Vietnam to collect any "top-up tax" required to meet this 15% minimum, rather than allowing another country (e.g., the MNE's parent company jurisdiction) to collect it.
  5. Scope: The rules apply to constituent entities (like subsidiaries or permanent establishments) located in Vietnam that are part of an MNE group with annual consolidated revenue of €750 million or more in at least two of the four preceding fiscal years.
  6. Guidance: The government was tasked with issuing further decrees to provide detailed guidance on implementation. A draft decree was released for consultation in late 2024.
  7. Compliance: Declarations and payments for the QDMTT are generally due 12 months after the end of the relevant fiscal year (meaning the first payments for the 2024 fiscal year would be due around the end of 2025).

In summary, Vietnam has adopted a Qualified Domestic Minimum Top-up Tax (QDMTT) effective from 2024, aligning with the OECD Pillar Two framework to ensure large multinational groups pay a minimum 15% tax on their Vietnamese income.


https://www.oecd.org/en/topics/sub-issues/global-minimum-tax/global-anti-base-erosion-model-rules-pillar-two.html

https://www.deloitte.com/southeast-asia/en/services/tax/perspectives/pillar-two-mne-in-en.html

https://www.amchamvietnam.com/events/flash-update-on-the-vietnams-draft-decree-on-global-minimum-tax-2024/

https://taxsummaries.pwc.com/vietnam/corporate/significant-developments

https://www.taxathand.com/article/33974/Vietnam/2023/National-Assembly-approves-resolution-to-introduce-global-minimum-tax#:~:text=and%20IIR%20rules%3A-,QDMTT,ETR%20of%20less%20than%2015%25.


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