Estimated revenue of tens of trillions of VND from global minimum tax.

The application of supplementary corporate income tax under the global anti-base erosion regulation was officially approved at the 8th session of the 15th National Assembly. The detailed regulations are currently being urgently drafted by the Ministry of Finance .

Estimated revenue of tens of trillions of VND from global minimum tax.

The application of supplementary corporate income tax under the global anti-base erosion regulation was officially approved at the 8th session of the 15th National Assembly . The detailed regulations are currently being urgently drafted by the Ministry of Finance.

Estimated revenue of tens of trillions of VND.

This morning, the Vietnam Chamber of Commerce and Industry (VCCI) and the Ministry of Finance jointly organized a dialogue conference on tax and customs policies and administrative procedures in 2024. Resolution No. 107/2023/QH15 dated November 29, 2023, on the application of supplementary corporate income tax under the global anti-base erosion regulations, is one of the notable new contents regarding tax policies and administrative procedures in 2024.

The Resolution on the application of supplementary corporate income tax under the global anti-base erosion regulation comprises 8 Articles and 1 Annex. Notably, the Resolution stipulates that taxpayers who are constituent entities of multinational corporations with consolidated financial statements of the ultimate parent company showing revenue of €750 million or more in at least two of the four consecutive years preceding the fiscal year, except in certain specified cases, are eligible for this tax.

The Resolution stipulates two provisions regarding the application of supplementary corporate income tax. Specifically, it stipulates a minimum domestic tax rate (QDMTT) applicable to constituent entities or groups of constituent entities of the aforementioned multinational corporation, which conduct business activities in Vietnam during the fiscal year.

The aggregate minimum taxable income (IIR) regulation applies to the ultimate parent company, partially owned parent company, and intermediate parent company in Vietnam that is a constituent entity of the aforementioned multinational corporation, directly or indirectly holding ownership of a low-tax-rate constituent entity abroad according to the Global Minimum Tax Regulation at any point in the fiscal year.

The minimum tax rate stipulated in the Resolution is 15%. According to information presented at the Conference, based on the 2022 corporate income tax settlement data, the General Department of Taxation preliminarily calculated that approximately 122 foreign corporations investing in Vietnam would be affected by the Regulation on Minimum Domestic Production Standards (QDMTT). The estimated additional tax revenue from this group is approximately VND 14,600 billion.

According to preliminary calculations based on corporate income tax settlement data for 2022, if Vietnam applies the minimum taxable income (IIR) regulation, six Vietnamese corporations would be subject to it. The additional corporate income tax that Vietnam could collect is estimated at nearly 73 billion VND (assuming the host countries do not apply the IIR).

The draft decree providing detailed regulations is being urgently prepared.

According to the Resolution, taxpayers must file information returns in accordance with the Global Minimum Tax Regulations, and supplementary corporate income tax returns accompanied by an explanatory statement on differences due to variations between financial accounting standards.

Regarding the deadlines for filing and paying taxes, the minimum domestic supplementary corporate income tax (QDMTT) requirement is 12 months after the end of the fiscal year. For the minimum aggregate taxable income (IIR) requirement, it is 18 months after the end of the fiscal year for the first year the group is subject to the regulations; and 15 months after the end of the fiscal year for subsequent years.

Currently, the Ministry of Finance (General Department of Taxation) is urgently developing a Decree detailing the contents assigned in the Resolution to ensure full legal basis, consistency, and uniformity with the provisions of the Resolution for implementation. The Ministry of Finance has issued Official Letter No. 12367/BTC-TCT dated November 12, 2024, requesting opinions on the draft Decree detailing Resolution No. 107/2023/QH15 dated November 29, 2023.

Source: https://baodautu.vn/uoc-thu-hang-chuc-nghin-ty-dong-tu-thue-toi-thieu-toan-cau-d232076.html