Global Minimum Tax (GMT) – Part 2: Declaration, Payment Of Top-Up Corporate Income Tax (CIT) And Practical Considerations

After completing the tax registration process, the next step – and also the most complex one for multinational groups – is fulfilling the obligation to declare and pay the Top-up Corporate Income Tax (CIT).

Below is detailed guidance on required documentation and statutory deadlines under the latest regulations.

I. Top-up CIT Declaration Dossier under GMT

Depending on the mechanism applied by the group (QDMTT or IIR), the required documentation will differ. Enterprises should carefully prepare the following:

1. In case of applying Qualified Domestic Minimum Top-up Tax (QDMTT)

• GMT Information Return – Form No. 01/TKTT-QDMTT
• Top-up CIT Return – Form No. 01/TNDN-QDMTT
• Explanatory Statement on Accounting Standard Differences – Form No. 01/TM
• GMT Information Return of the Multinational Enterprise (MNE) Group
• Financial data reports of each constituent entity in Vietnam
• Consolidated financial statements of the Ultimate Parent Entity (UPE)

2. In case of applying Income Inclusion Rule (IIR)

• GMT Information Return – Form No. 01/TKTT-IIR
• Top-up CIT Return – Form No. 01/TNDN-IIR
• Explanatory Statement on Differences – Form No. 01/TM
• Consolidated financial statements of the Ultimate Parent Entity
• Financial data reports of each constituent entity for consolidation purposes

II. Filing Deadlines

The GMT filing deadlines are longer than those applicable to standard Corporate Income Tax, reflecting the complexity of consolidating financial data on a global scale.

III. Place, Method and Tax Payment Obligations

• Receiving Authority: Large Enterprise Tax Department
• Filing Method: Fully electronic submission
• Tax Payment: Top-up CIT is paid into the Central State Budget
• Overpayment Handling: Offset or refund of overpaid tax shall be conducted in accordance with general tax administration regulations

IV. Practical Considerations for Enterprises

Based on practical advisory experience, TPM recommends that enterprises focus on three key areas:

1.             Data Alignment
   Establish continuous coordination between the accounting team in Vietnam and the Group’s Tax/Finance department to ensure consistency between consolidated figures and locally declared data.
2.             Accounting Standards Review
   Differences between VAS and IFRS (or the accounting standards applied by the UPE) may result in significant discrepancies in the top-up tax calculation. Early reconciliation is strongly recommended.
3.             Compliance Chain Control
   Tax registration, notification of constituent entities, and tax filing form a continuous compliance chain. Even a minor error at the notification stage may cause the tax return to be rejected by the tax authority’s system.

V. Conclusion

The implementation roadmap of the Global Minimum Tax (GMT) requires thorough preparation and close coordination on a multinational scale. A solid understanding of required forms and statutory deadlines enables enterprises to proactively manage financial planning and ensure strict compliance.

To ensure accuracy and optimization throughout the registration and filing process of the Global Minimum Tax, TPM is honored to accompany your enterprise with in-depth review solutions and comprehensive GMT filing support.

Quyen Nguyen