Jurisdictions › Vietnam
Enacted

Vietnam Pillar Two

Asia-Pacific

Effective
Jan 2024
QDMTT local name
Qualified Domestic Minimum Top-up Tax (QDMTT)
IIR
Not adopted
✕ Not adopted
UTPR
Not adopted
✕ Not adopted
QDMTT
Qualified Domestic Minimum Top-up Tax (QDMTT)
Enacted
In development — This profile is provided for reference only and may contain inaccuracies. Always verify against official legislation and current OECD guidance.
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 →