Vietnam Decree for Implementation of Pillar 2 Global Minimum Tax Rules, Including Compliance Obligations

Vietnam's Government has announced the release of Decree No. 236/2025/ND-CP for the implementation of Resolution No. 107/2023/QH15. The Resolution, approved in November 2023, provided for the introduction of Pillar 2 global minimum tax (GloBE) rules with effect from 1 January 2024, including an Income Inclusion Rule (IIR) and a Qualified Domestic Minimum Top-up Tax (QDMTT) (previous coverage). Among other things, the decree covers the compliance obligations and deadlines for the new rules: