Supplementary enterprise income tax to multinational corporation from October 15, 2025

This is provided in Decree No. 236/2025/ND-CP detailing the implementation of Resolution No. 107/2023/QH15 on the application of supplementary enterprise income tax under the global anti-base erosion rules.

Article 3 of Decree No. 236/2025/ND-CP prescribes cases subject to supplementary enterprise income tax as follows:

Constituent entities of multinational groups with consolidated revenue of the ultimate parent company of EUR 750 million or more per year, reaching this threshold in at least 2 of the 4 fiscal years preceding the fiscal year in which tax liability is determined.

For newly established groups, only 2 fiscal years meeting the revenue threshold are required.

enterprise income tax for multinational corporations

This does not apply to exclusions specified in Clause 1, Article 2 of Resolution No. 107/2023/QH15 and Clause 3, Article 3 of Decree No. 236/2025/ND-CP.

Revenue equivalent to EUR 750 million or more is determined based on the consolidated revenue of the ultimate parent company in the following cases:

  • Fiscal year shorter than 12 months: the EUR 750 million threshold is prorated according to the actual number of days/365 days.

  • Merger or consolidation of groups:
    • If multiple groups merge: the threshold is based on the total consolidated revenue of the parties before the merger.
    • If independent entities merge into a group: revenue is the sum of each entity’s revenue in the financial statements.
    • If an entity merges into an existing group: revenue is the consolidated revenue of the entity and the group.

  • Division or separation of groups:
    • First fiscal year after division/separation: consolidated revenue must reach the EUR 750 million threshold (adjusted if less than 12 months).
    • From the second to fourth fiscal years after division/separation: at least 2 fiscal years must meet the revenue threshold.

Starting from October 15, 2025, multinational groups falling under the above cases must declare and pay supplementary enterprise income tax in accordance with the global minimum tax mechanism.

1900 6192 để được giải đáp qua tổng đài
090 222 9061 để sử dụng dịch vụ Luật sư tư vấn (CÓ PHÍ)
Đánh giá bài viết:

Tin cùng chuyên mục

English translation of the 2025 Law Amending the Law on Treaties, No. 137/2025/QH15 is newly published

English translation of the 2025 Law Amending the Law on Treaties, No. 137/2025/QH15 is newly published

English translation of the 2025 Law Amending the Law on Treaties, No. 137/2025/QH15 is newly published

The 2025 Law Amending the Law on Treaties, No. 137/2025/QH15, will take effect on January 01, 2026. This Law focuses on reforming processes for the conclusion, accession to, and implementation of international commitments to enhance international integration efficiency and ensure the consistency of the legal system in the new context.

 

The English translation of Law Amending and Supplementing the Law on Judicial Records has been published

The English translation of Law Amending and Supplementing the Law on Judicial Records has been published

The English translation of Law Amending and Supplementing the Law on Judicial Records has been published

The Law Amending and Supplementing a Number of Articles of the Law on Judicial Records 2025, No. 107/2025/QH15, shall take effect on July 01, 2026, and focuses on amending key provisions to create a synchronous legal framework for judicial record management in the new period.

 

Strategy to help enhance Vietnam’s prestige, appeal on international arena

Strategy to help enhance Vietnam’s prestige, appeal on international arena

Strategy to help enhance Vietnam’s prestige, appeal on international arena

The target is set out in the Government’s strategy to promote Vietnam’s global image for the 2026–2030 period, with a vision to 2045, approved by the Prime Minister on January 27. The strategy underlines that promoting Vietnam's image abroad is not merely information activities, but a strategic "soft" tool serving the country's development.

List of special-purpose machinery serving agricultural production to 5% VAT from December 31, 2025

List of special-purpose machinery serving agricultural production to 5% VAT from December 31, 2025

List of special-purpose machinery serving agricultural production to 5% VAT from December 31, 2025

The Minister of Agriculture and Environment has promulgated Circular No. 101/2025/TT-BNNMT on providing guidance on other special-purpose machinery serving agricultural production not yet specified in Clause 6, Article 19 of the Government’s Decree No. 181/2025/ND-CP dated July 01, 2025, detailing a number of articles of the Law on Value-Added Tax.