Vietnam Pillar Two obligations

A 30-day notification and a 90-day registration run far ahead of the returns, and the QDMTT return falls at 12 months rather than the usual 15.

What is in force in Vietnam

The 4 separate filing obligations

Penalties

Decree 236 cites the Law on Handling of Administrative Violations No. 56/2024/QH15 as the basis but states no amounts. Transitional relief is explicit: Art. 11(4) disapplies administrative tax penalties for listed acts during the transition period, including notifications and registrations up to 90 days late. The transition period runs to fiscal years ending on or before 31 December 2026 and does not extend beyond 30 June 2028. Art. 11(5) confirms the underlying obligations still stand.

What catches groups out in Vietnam

• The QDMTT return falls at 12 months, earlier than almost anywhere else — for a December 2025 year end that is 31 December 2026.
• The transitional penalty shield lapses for fiscal years ending after 31 December 2026, so the next cycle is the first with full exposure.
• Decree 236 names an electronic transaction portal but does not identify it, so the channel is not confirmed.

Recent changes affecting Vietnam

• 2026-12-31 — Vietnam's QDMTT return and top-up tax return fall due 12 months after fiscal year end, not the 15 months that applies almost everywhere else. For a December 2025 year end that is 31 December 2026.
• 2026-12-31 — Vietnam's transitional penalty shield covers fiscal years ending on or before 31 December 2026, disapplying administrative penalties for listed acts including notifications and registrations up to 90 days late. The underlying obligations still stand.

All dated changes →

Common questions

What must be filed in Vietnam under Pillar Two?

4 separate obligations: Thông báo đơn vị hợp thành chịu trách nhiệm kê khai; Tờ khai đăng ký thuế; Tờ khai thông tin theo Quy định về thuế tối thiểu toàn cầu; Tờ khai thuế thu nhập doanh nghiệp bổ sung.

When is the Thông báo đơn vị hợp thành chịu trách nhiệm kê khai due in Vietnam?

Within 30 days after the end of the reporting fiscal year. Change of filing entity: within 10 days of the event. Filed by: The group. Channel: In person, by post, or the tax authority's electronic transaction portal.

When is the Tờ khai đăng ký thuế due in Vietnam?

No later than 90 days after the end of the reporting fiscal year. Changes within 10 working days. Filed by: The designated filing entity. Channel: In person, by post, or the tax authority's electronic transaction portal.

What access is needed before filing in Vietnam?

10-digit tax code for the filing entity (Mẫu số 01-MST-ĐVHT). The tax code is the prerequisite for filing and paying. A successor filing entity inherits the existing code. If the group does not notify its filing entity, the tax authority designates one and the designated entity must respond within 10 days.

What are the penalties in Vietnam?

Decree 236 cites the Law on Handling of Administrative Violations No. 56/2024/QH15 as the basis but states no amounts. Transitional relief is explicit: Art. 11(4) disapplies administrative tax penalties for listed acts during the transition period, including notifications and registrations up to 90 days late. The transition period runs to fiscal years ending on or before 31 December 2026 and does not extend beyond 30 June 2028. Art. 11(5) confirms the underlying obligations still stand.

Where this comes from

Every row on this page was checked against the authority's own published page on 10 October 2026. Resolution 107/2023/QH15 and Decree 236/2025/NĐ-CP were both read in official government-hosted copies. The filing portal is named in the decree only as 'the electronic transaction portal' and is not confirmed to be the existing eTax system; penalty amounts sit in the general administrative penalty decree, which was not read.

Other Pillar Two jurisdictions

United Kingdom · Ireland · Netherlands · Belgium · Germany · Spain · Italy · Luxembourg

All 31 entries in the tracker →