Vietnam: Guidance on implementation of Pillar Two rules

Guidance on compliance obligations and administrative procedures for both IIR and QMDTT

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September 4, 2025

The government on August 29, 2025, issued Decree No. 236/2025/ND-CP (effective October 15, 2025) providing detailed guidance on the implementation of the Pillar Two global minimum tax rules, including key compliance obligations and administrative procedures for multinational enterprise (MNE) groups.

The decree, which follows the adoption of Resolution No. 107/2023/QH15 (effective January 1, 2024), covers both the income inclusion rule (IIR) and the qualified domestic minimum top-up tax (QDMTT).

Read a September 2025 report prepared by the KPMG member firm in Vietnam

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