Vietnam · Tax, Finance & Audit

Vietnam's standard CIT rate is 20%; BOI zones reduce it to 10% or 15% with exemption/reduction periods. But from 2024 the global minimum tax (QDMTT) tops large MNEs' effective rate to 15%, significantly eroding the benefit for Chinese manufacturers (mainly electronics) in Vietnam.

Key points

CIT: standard 20%; BOI zones 10% (10–15 years) or 15%, with tax-free and halved periods.
VAT: standard 10% (some 5% or 0%).
Global minimum tax: from 2024 for groups with ≥ €750M global revenue, tops up to 15% ETR; Vietnam has enacted QDMTT.
Foreign Contractor Tax (FCT): paid by the payer on behalf of foreign service suppliers.
Transfer-pricing and Country-by-Country Reporting (CbCR) obligations.

Procedure

Tax registration (parallel with ERC).
Determine QDMTT scope and top-up tax.
Annual CIT/VAT/FCT filing.
Large groups file CbCR and GloBE information return.
Audit threshold by annual revenue.

Hard requirements

Local bookkeeping; large groups GloBE filing; substance must match incentive conditions.

Costs

Taxes per rules; the minimum-tax-eroded portion is the real incremental cost.⏱ ⏱ Timeline：Annual filing; minimum tax applicable from FY2024.

⚠ Common risks

BOI benefit topped to 15% — real CIT can rise ~50% (from 10%).
Unsatisfied incentive conditions → incentive reclaimed.
Transfer-pricing adjustments.

Handbook

📘 Step-by-Step Handbook (with owner / timeline / cost / penalties)

Applies to：Tax compliance and annual filing for Chinese-invested entities in Vietnam (incl. BOI manufacturers). Highlights the material impact of the global minimum tax (QDMTT) on large MNE groups.

Prerequisites

Vietnam entity completed tax registration (parallel with ERC).
Local bookkeeping (Vietnam accounting standards) established.
Determine QDMTT scope (consolidated revenue ≥ €750M and ≥ 2 of past 4 years).
BOI incentive conditions (export ratio, local content) clarified.

Step	Action	Owner	Timeline	Cost	Official form / system	Notes & penalties
1	Tax registration and chart of accounts After ERC, complete tax registration, set up Vietnam-standards ledger, set fiscal year and invoice system (e-invoice).	Finance + Vietnam accountant	Setup phase	Accounting service fee	Tax registration & ledger	CIT standard 20%, VAT standard 10% Penalty：No registration or no e-invoice → penalty
2	Determine QDMTT (GloBE) scope Cross-check Resolution 107/2023/QH15 and Decree 236/2025/ND-CP: group in GloBE scope (consolidated revenue ≥ €750M and ≥ 2 of past 4 years); measure the Vietnam entity ETR.	Group tax + Big Four/advisor	1–3 months before FY end	Advisor fee	GloBE scope test & ETR measurement	Vietnam QDMTT effective 2024-01-01; Decree 236/2025 effective 2025-10-15; substantive filing from 2026 Penalty：Non-filing top-up tax fined (transitional relief needs good-faith compliance)
3	BOI incentive application and maintenance For encouraged sectors or zones, apply BOI (CIT 10% or 15% plus exemption/reduction); satisfy export-ratio, local-content conditions; account separately.	Company + investment promotion	Setup & ongoing	Low application fee	BOI incentive decision	QDMTT tops BOI to 15% — large groups no longer materially below 15% Penalty：Unsatisfied conditions → reclaim减免 + 5%–10% of investment fine
4	Annual CIT/VAT/FCT filing After FY end, file CIT (standard 20%), VAT (10%), FCT (withheld on foreign suppliers); large groups file CbCR and GloBE information return.	Finance + tax agent	3–4 months after FY end	Filing fee	CIT/VAT/FCT + CbCR + GloBE	2026 transition CbCR safe-harbour simplified ETR threshold 17% Penalty：Late filing fine and interest
5	Audit and transfer pricing Audit by annual-revenue threshold; related-party transactions need TP documentation per arm's-length principle.	Company + auditor	Annual	Audit fee	Audit report & TP docs	Substance must match incentive to avoid adjustment Penalty：TP adjustment top-up tax and fine

✅ Self-check list

Tax registration and e-invoice done. Local ledger (Vietnam standards) established. QDMTT GloBE scope determined. BOI incentive applied and conditions met. CIT/VAT/FCT filed on time. Large groups filed CbCR and GloBE information return. Audit and TP documentation ready. Local TP contemporaneous docs prepared (threshold → local file + CbCR).

⚠ Common pitfalls

BOI benefit topped to 15%影响：From 10% the real CIT can rise ~50%; investment model fails.规避：Pre-investment GloBE ETR modelling; reduce top-up via substance carve-out (payroll/tangible assets).

Incentive conditions unmet → reclaimed影响：Reclaim减免 + 5%–10% fine.规避：Strictly meet export-ratio/local-content; account separately; file annual maintenance report by 31 March.

Transfer-pricing adjustment影响：Top-up tax + fine.规避：Prepare TP docs; related parties at arm's length.

Ignoring QDMTT filing duty影响：Transitional relief needs good-faith compliance or is lost.规避：From 2026 build GloBE measurement and filing process; designate the Vietnam filing entity.

Non-statutory e-invoice or false invoice info影响：GDT penalty, input VAT disallowed, tax-evasion suspicion.规避：Use Vietnam e-invoice system (tax-connected software); invoice info matches actual transaction.

📅 Ongoing post-incorporation obligations

Annual CIT/VAT/FCT filing.
Large groups CbCR and GloBE information return (QDMTT).
BOI annual maintenance report (by 31 March each year).
Audit (above threshold) and TP documentation.
Monitor incentive-condition continuity.

🔗 Official portals

General Department of Taxation (GDT)Ministry of Planning and Investment (MPI)OECD Global Minimum Tax (BEPS Pillar Two)

📎 Source：https://www.gdt.gov.vn ; https://www.oecd.org/tax/beps/

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