Analyses & Studies • Members
Forvis Mazars: Global Minimum Tax, First return deadline approaching
Now that September has arrived, 2025 year-end tax compliance is coming into view, with the deadline for the first return – the Qualified Domestic Top-Up Tax (“QDMTT”) – under the Global Minimum Tax (“GMT”) mechanism. This applies to Vietnamese entities of multinational groups whose fiscal year is aligned with the calendar year.
For a recap on the GMT rules, we refer to our previous updates.
QDMTT
The introduction of QDMTT allows Vietnam to levy a top-up tax when tax residents falling under the scope of GMT do not reach the minimum effective tax rate of 15%. QDMTT is assessed on a jurisdictional basis, meaning that if several entities are present in Vietnam, they are all taken into account in the calculation.
To determine whether an entity is subject to the 15% effective tax rate, the GMT rules (as introduced in Resolution 107/2023/QH15 of the National Assembly, with further guidance expected) provide for a specific set of measures, starting with the financial statements prepared for consolidation purposes. Subsequently, specific adjustments, exclusions, and additions must be made in order to determine the relevant income, the effective tax rate, and any potential top-up tax payable.
The QDMTT will be considered zero if an entity, or a group of entities within the same jurisdiction, falls within the scope of the safe harbour rules (i.e., the de minimis test, the effective tax rate test, and the routine profit test). The deadline for filing the QDMTT return, even if the QDMTT is determined as zero, is 12 months from fiscal year-end.
Given the complexity of the calculations required under the GMT rules, transitional provisions have been introduced for the years 2024, 2025, and 2026. These allow for a more simplified approach to determine whether an entity is subject to QDMTT, using the entity’s Country-by-Country Report as a starting point.
Action required
Although further guidance under Resolution 107 has not yet been published, the deadline for the first QDMTT return is approaching. It is therefore time to assess whether your Vietnamese entity or group of entities falls within the scope of the safe harbour rules. An initial assessment can be carried out based on the GMT rules published by the OECD and your group’s Country-by-Country Report.
For any questions on GMT, we are available to assist. Please feel free to reach out to our experts.
Our supports
To strengthen our expertise in international tax and Global Minimum Tax, we are delighted to announce that Anne-Jet Klaver has recently joined Forvis Mazars as Senior Manager in our Tax team. She brings more than ten years of experience in international taxation, gained both as an advisor at a Big Four firm and as in-house tax manager for a large multinational, working across a variety of sectors and clients.
At Forvis Mazars, she will focus on Global Minimum Tax, helping clients navigate the complexities of these globally introduced rules and supporting them with the compliance process specific to Vietnam. She also enhances our ability to advise clients on broader international tax issues connected to doing business in Vietnam.
As an active member of the Dutch community in Vietnam, she is also committed to strengthening business ties between the two countries.
Please feel free to contact us if you need any support.
Contacts:
Minh Nguyen – Partner, Head of Advisory – minh.nguyen(@)forvismazars.com
Da Nguyen – Partner, Tax – da.nguyen(@)forvismazars.com
Anne-Jet Klaver – Senior Manager, Tax – anne-jet.klaver(@)forvismazars.com
Anh Tran – Manager, Tax – anh.trantuan(@)forvismazars.com
