Vietnam

Vietnam witnessed significant recent developments related to base erosion and profit shifting (BEPS, including MLI and Pillar Two - Global Minimum Tax) and e-commerce activities. More importantly, Vietnam has made significant efforts to reform a number of key tax laws. Please refer to the Taxes on corporate income section for comments relating to Pillar Two.

Taxing e-commerce activities

In September 2021, the Ministry of Finance (MoF) officially issued Circular 80/2021/TT-BTC (Circular 80) providing detailed guidance on the Law on Tax Administration on various matters, which also have a chapter focus on the tax filing mechanism for foreign companies doing e-commerce, digital business, and other business in Vietnam without a permanent establishment (PE). The General Department of Taxation (GDT) officially launched the portal for direct tax registration, declaration, and payments by e-commerce companies in Vietnam on 21 March 2022. 

According to the new Law on Corporate Income Tax (CIT), which took effect from 1 October 2025, foreign companies using e-commerce and digital platforms to supply goods/services in Vietnam are now formally included within the scope of the new CIT Law. In addition, these platforms are now officially included in the definition of PEs, potentially impacting double taxation agreement (DTA) exemption claims.

BEPS landscape

On 9 February 2022, Vietnam signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (‘the Convention‘ or ’the MLI‘), becoming the 99th jurisdiction to join the Convention. As a result, most of Vietnam’s DTAs were amended once the MLI entered into effect. Taxpayers should be aware of these changes to DTAs and the impact this may have on their plans for structuring their investments and transactions to claim treaty benefits in Vietnam.

In May 2023, Vietnam deposited its instrument of ratification for the MLI (BEPS Convention). The BEPS Convention entered into force on 1 September 2023 for Vietnam.

Pillar 2 - Global Minimum Tax

On 29 November 2023, the Resolution on Global Minimum Tax policy in Vietnam (“the Resolution”) was finally approved by the National Assembly and came into effect from 1 Jan 2024.

The Resolution provides that Vietnam will adopt (i) the Qualified Domestic Minimum Top-Up Tax (“QDMTT”) rule and (ii) the Income Inclusion Rule (“IIR”). Both rules are intended to protect Vietnam’s tax revenue in the context of Pillar 2 global implementation. The QDMTT rule targets foreign inbound investment while the IIR targets Vietnam’s outbound investment.

Following the OECD’s Global Anti-Base Erosion (“GloBE”) rules, the top-up tax will be paid to the central state budget, unlike corporate income tax which is shared between central and provincial state budgets.

Tax filing obligations:

• The submission deadlines are as follows:
  • For QDMTT: 12 months after the fiscal year end.
  • For IIR: 18 months after the fiscal year end for the first fiscal year in scope and 15 months for subsequent fiscal years in scope.
• The tax payment deadline is the same as the filing deadline.

Safe harbour and penalty relief:

The Resolution introduces a transitional country-by-country report (“CbCR”) safe harbour rule that is the same as that in the OECD’s GloBE rules.

The Ministry of Finance in Vietnam has released a decree on the global minimum tax, aligning with international efforts to create a fairer taxation system and address issues like base erosion and profit shifting. For more detailed information and the most recent updates, please visit PwC’s Pillar Two Country Tracker.