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This is provided in Decree No. 236/2025/ND-CP detailing the implementation of Resolution No. 107/2023/QH15 on the application of supplementary enterprise income tax under the global anti-base erosion rules.
Article 3 of Decree No. 236/2025/ND-CP prescribes cases subject to supplementary enterprise income tax as follows:
Constituent entities of multinational groups with consolidated revenue of the ultimate parent company of EUR 750 million or more per year, reaching this threshold in at least 2 of the 4 fiscal years preceding the fiscal year in which tax liability is determined.
For newly established groups, only 2 fiscal years meeting the revenue threshold are required.
This does not apply to exclusions specified in Clause 1, Article 2 of Resolution No. 107/2023/QH15 and Clause 3, Article 3 of Decree No. 236/2025/ND-CP.
Revenue equivalent to EUR 750 million or more is determined based on the consolidated revenue of the ultimate parent company in the following cases:
Fiscal year shorter than 12 months: the EUR 750 million threshold is prorated according to the actual number of days/365 days.
Merger or consolidation of groups:
• If multiple groups merge: the threshold is based on the total consolidated revenue of the parties before the merger.
• If independent entities merge into a group: revenue is the sum of each entity’s revenue in the financial statements.
• If an entity merges into an existing group: revenue is the consolidated revenue of the entity and the group.Division or separation of groups:
• First fiscal year after division/separation: consolidated revenue must reach the EUR 750 million threshold (adjusted if less than 12 months).
• From the second to fourth fiscal years after division/separation: at least 2 fiscal years must meet the revenue threshold.
Starting from October 15, 2025, multinational groups falling under the above cases must declare and pay supplementary enterprise income tax in accordance with the global minimum tax mechanism.
