Global Minimum Tax (GMT) – Part 1: Applicable Entities, Designation Notice And Tax Registration

On 29 August 2025, the Government issued Decree No. 236/2025/NĐ-CP, marking a major turning point in tax governance for multinational enterprise groups in Vietnam. The Decree takes effect from 15 October 2025 and applies retroactively to fiscal years starting from 2024.

I. Identification of constituent entities responsible for GMT filing

Taxpayers are constituent entities of a multinational enterprise group (MNE) whose ultimate parent entity has consolidated revenue of at least EUR 750 million in at least 2 of the 4 preceding fiscal years.

The allocation of filing and payment responsibilities is as follows:

• Where the Group has only one constituent entity in Vietnam:
  That entity directly performs tax registration, filing, and payment of the top-up corporate income tax.
• Where the Group has two or more constituent entities in Vietnam:
  The Group must designate one constituent entity in Vietnam to act as the focal point responsible for tax registration, filing, and payment on behalf of all domestic constituent entities.

This designation is mandatory to ensure unified tax compliance within Vietnam.

II. Notification of the designated filing entity and list of constituent entities

1. Notification deadlines

According to Article 14 of Decree 236/2025/NĐ-CP:

• Initial notification: Within 30 days from the end of the reporting fiscal year;
• In case of changes: No later than the deadline for filing the tax return of the fiscal year in which the change arises.
  

2. Notification form: Form No. 01/TB-ĐVHT issued together with Decree 236/2025/NĐ-CP.
3. Special cases

For the following structures:

• Joint ventures that are not members of a joint venture group;
• Joint venture groups;
• Sub-groups or constituent entities whose ultimate parent entity is a minority owner,
  

If they fall within the scope of the Qualified Domestic Minimum Top-up Tax (QDMTT), they must still submit notification designating the responsible filing entity and the list of constituent entities under separate regulations.

III. Tax registration under Global Minimum Tax regulations

1. Entities required to register

• The designated constituent entity responsible for filing;
• Entities subject to QDMTT;
• The designated filing company of a joint venture group;
• Constituent entities of a sub-group or entities whose ultimate parent is a minority owner.

2. Tax identification number

The tax authority issues a separate 10-digit tax identification number specifically for GMT obligations.

This tax code is used consistently throughout the filing, payment, and finalization of Global Minimum Tax obligations.

If the designated filing entity changes, the new entity inherits all tax obligations and continues using the previously issued tax code.

3. Registration timeline and dossier

• Registration form: Form No. 01-ĐKTD-ĐVHT;
• Initial registration deadline: No later than 90 days from the end of the reporting fiscal year;
• Changes to registration information: Within 10 working days from the date the change occurs.

Note: For the special case where fiscal year 2024 ends on or before 30 June 2025, the deadline is 90 days from the effective date of Decree 236/2025/NĐ-CP, but not later than the tax filing deadline.

4. Supervising authority and method

• Supervising authority: Large Enterprise Tax Department;
• Method: Through the electronic portal of the tax authority.

Correctly identifying applicable entities, properly designating the responsible filing entity, and timely tax registration form the foundation for compliance with Global Minimum Tax in Vietnam. Errors or delays at this stage may lead to filing risks, payment issues, and legal liabilities.

Stay tuned for Part 2, where TPM will guide enterprises through filing dossiers, deadlines, and payment obligations related to the Global Minimum Tax, along with key practical considerations.

Quyen Nguyen