Official Letter No. 6450/BNI-QLDN1 was issued to guide FDI enterprises in the context of applying global minimum tax, a new tax mechanism that directly affects investment strategies, profit structures and tax incentives. With the aim of ensuring fairness in the international competitive environment, this document helps enterprises clearly understand the scope of subjects, tax calculation criteria and compliance responsibilities, thereby proactively preparing appropriate financial solutions.
Overview of global minimum tax according to Official Letter No. 6450/ BNI-QLDN1
The document begins by emphasizing the goal: to guide businesses to promptly declare and pay global minimum tax according to OECD standards. Bac Ninh is a locality with many large corporations in the fields of electronics, assembly, and high technology, so the risk of falling into the GMT range is very high.
According to Official Letter No. 6450/ BNI-QLDN1, the global minimum tax in Vietnam follows two main pillars:
- QDMTT – Standard Minimum Additional Corporate Income Tax
- IIR – Comprehensive Minimum Taxable Income Tax
The application of GMT ensures that Vietnam collects the difference if the effective tax rate (ETR) of enterprises in Vietnam is below 15%.
Applicable subjects in Official Dispatch No. 6450/ BNI-QLDN1
According to the document, businesses subject to GMT in Vietnam include:
- Multinational corporations with a minimum consolidated turnover of EUR 750 million in at least 2 of the 4 consecutive years preceding the financial year under review
- Has a constituent unit operating in production and business in Vietnam
- Applicable from fiscal year 2024, effective from October 15, 2025
Official dispatch No. 6450/ BNI-QLDN1 It should also be noted that businesses other than the ultimate parent company are still obligated to provide data as requested by the constituent entity responsible for declaration.
The principles for calculating QDMTT are guided in Official Dispatch No. 6450/ BNI-QLDN1
QDMTT (Qualified Domestic Minimum Top-up Tax) is a domestic minimum tax mechanism that Vietnam applies to ensure effective tax collection.
According to Official Dispatch No. 6450/ BNI-QLDN1, enterprises need to:
- Determining corporate income tax according to OECD standards (adjusted)
- Calculate net income and adjusted income
- Substance depreciation calculation: tangible assets + payroll costs
- Determine the additional tax rate QDMTT if the effective tax rate < 15%
New and important points in the document:
- All constituent entities in Vietnam are grouped together to determine ETR, rather than separating each company separately.
- Tax declaration and payment are the responsibility of the assigned constituent unit, but it must consolidate data from all units of the group in Vietnam.
The formula for calculating additional tax is stated in Official Dispatch No. 6450/ BNI-QLDN1
According to the official document:
- Calculate adjusted net income
- Calculate actual corporate income tax paid (after adjustment)
- Calculate ETR = Corporate Income Tax / Adjusted Income
- Compare to level 15%
- If difference > 0 → additional tax arises
- Substance deductions according to official dispatch
Official document No. 6450/BNI-QLDN1 also lists specific cases affecting the calculation formula, such as: minority parent companies, mergers - asset transfers, joint ventures, etc.
Case of "additional tax equal to 0" according to official dispatch no. 6450/ BNI-QLDN1
The document emphasizes that if the enterprise meets the requirements OECD simplified criteria such as:
- Average revenue does not exceed the threshold for each market
- Low average income
→ The additional tax may be zero.
This is the content that small and medium-sized FDI enterprises in Bac Ninh need to pay special attention to.
The IIR mechanism is explained in document number 6450/BNI-QLDN1.
IIR (Income Inclusion Rule) is a tax mechanism applied at the parent company level.
According to Official Dispatch No. 6450/ BNI-QLDN1, IIR is applied to:
- The ultimate parent company in Vietnam
- Partially owned parent company
- Intermediary parent company
Order of priority:
- Partially owned parent company
- Ultimate parent company
- Intermediary parent company
If a Vietnamese parent company owns a low-tax subsidiary abroad, Vietnam will collect the additional tax.
Regulations on transfer, joint venture... according to official dispatch no. 6450/ BNI-QLDN1
The document devotes a large part to explaining:
- Regulations for minority parent companies
- Joint venture
- Transfer of assets
- Transit unit
These are complicated cases, requiring businesses to review their corporate structure to properly apply the principles in Official Dispatch No. 6450/BNI-QLDN1.
Register, declare, and pay taxes according to official document No. 6450/BNI-QLDN1
To help businesses understand the process of implementing global minimum tax obligations in accordance with the instructions of Official Letter No. 6450/BNI-QLDN1, the table below summarizes all the types of documents that need to be prepared, the order of tax declaration and payment, and the deadline. Complying with these steps will help businesses avoid errors, ensure transparency, and meet the requirements of Decree 236/2025/ND-CP.
| Content | Details according to official dispatch no. 6450/ BNI-QLDN1 |
| Documents to prepare | • QDMTT Tax Return Form
• Effective Tax Rate (ETR) Statement • Tax adjustment appendices according to OECD standards • Summary table of data of constituent units in Vietnam |
| Implementation process | Step 1: Enterprises register for global minimum tax (GMT) declaration information
Step 2: Submit the QDMTT declaration form according to the prescribed form Step 3: Submit documents proving effective tax rate Step 4: Pay additional tax (if any) |
| Deadline for submitting documents and declarations | Submit within 12 months after the end of the fiscal year, pursuant to Decree 236/2025/ND-CP |
Special note for Bac Ninh enterprises according to official dispatch no. 6450/ BNI-QLDN1
Official letter issuing a warning to FDI businesses:
- Internal financial statements cannot be used to calculate GMT tax.
- The consolidated financial statements of the corporation must be used.
- Businesses must proactively contact the parent company to get data.
- Delay in providing information will lead to false declaration, collection or penalty.
Recommendations for implementation from document number 6450/BNI-QLDN1
To effectively implement the global minimum tax and comply with the regulations of Circular No. 6450/BNI-QLDN1, FDI enterprises in Bac Ninh need to take several steps simultaneously. The table below summarizes practical implementation recommendations, from establishing a working group, reviewing tax policies, standardizing data according to OECD standards, to coordinating with the parent company and consulting professionals, in order to ensure accurate and timely tax declarations and payments and minimize legal risks.
| Recommended content | Detailed description |
| Establish a GMT task force. | Enterprises should establish a specialized team to manage data, coordinate between accounting - legal - finance and the parent corporation, ensuring progress and accuracy when implementing GMT. |
| Review all current preferential tax policies | Review existing tax incentives (CIT incentives) to assess the impact of applying the QDMTT; prepare an adaptation plan if the tax incentives are no longer in effect. |
| Data extraction and standardization according to OECD standards. | Gather financial data as required: ETR, adjusted income, taxes paid, tangible assets, payroll expenses, etc., and standardize them according to OECD format to facilitate QDMTT/IIR calculations. |
| Perform an ETR Test (Effective Tax Rate Test). | Assess the effective tax rate for the constituent entity in Vietnam to determine the potential for additional tax liability; proactively develop a suitable budget plan. |
| Working directly with the parent company. | Require the parent company to provide consolidated financial statements, tax adjustment data, ownership information, and GMT spreadsheets in accordance with global standards; ensure the data is consistent and valid. |
| Consult with a professional. | It is advisable to work with international tax experts or GMT consulting firms to ensure accuracy in calculations and declarations, and to minimize the risk of violations as stipulated in Official Letter No. 6450/BNI-QLDN1. |
Conclude
Official Letter No. 6450/BNI-QLDN1 has provided detailed guidance on global minimum tax, helping FDI enterprises in Bac Ninh understand the regulations on QDMTT and IIR. Correctly understanding and applying these guidelines will help enterprises avoid the risk of false declaration, while optimizing tax obligations in a transparent and effective manner.
The guidelines in the document also emphasize the importance of data standardization, performing ETR testing, and close coordination with the parent company. For businesses facing difficulties in implementation, MAN – Master Accountant Network is ready to provide support. tax consulting services, full tax accounting and audit We provide in-depth, step-by-step support, from data analysis and tax calculation to filing and paying taxes in accordance with regulations.
This document is not only a legal tool but also a guideline for businesses in international tax management. Let MAN – Master Accountant Network accompany you, helping businesses accurately update regulations, optimize tax obligations and minimize risks, ensuring smooth business operations and long-term efficiency.
Service contact information at MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
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