Key implementation point
QDMTT only. Vietnam's preferential investment incentives (some at 0–5%) are among the most impacted globally — significant for manufacturing supply chain MNEs.
Implementation detail
- 01 Vietnam enacted QDMTT only via National Assembly Resolution 107, effective 1 January 2024.
- 02 IIR and UTPR not enacted — Vietnam focuses solely on collecting top-up on locally low-taxed income.
- 03 Vietnam's Investment Law offers extensive tax incentives (0–10% CIT rates for qualifying projects), making QDMTT very material.
- 04 Major impact on manufacturing FDI: Samsung, Intel, LG, Apple supply chain entities in Vietnam face QDMTT top-up on preferential rate income.
- 05 GDT (General Department of Taxation) issued detailed guidance including QDMTT computation instructions.
- 06 Vietnam signalled intent to redirect QDMTT revenue toward attracting higher-value FDI.
Enacted legislation
Resolution No. 107/2023/QH15
Track Vietnam rules against your live MNE
In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.
See it in the sandbox →