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MINISTRY OF
FINANCE OF VIETNAM
GENERAL DEPARTMENT OF TAXATION
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SOCIALIST
REPUBLIC OF VIETNAM
Independence – Freedom – Happiness
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No. 4994/TCT-CS
Re: Assessment of impacts of global minimum
tax
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Hanoi, November
08, 2023
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To:
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Reagarding the impacts of global minimum tax on corporations
having ultimate parent entities (UPEs) in Vietnam, General Department of
Taxation has issued and sent Official Dispatch No. 1939/TCT-CS dated 19/5/2023
to Departments of Taxation of provinces and centrally affiliated cities and
Major Enterprise Department of Taxation.
In order to ensure the adequacy of data reported to
the Ministry of Finance, the Government and the National Assembly of Vietnam,
Departments of Taxation need to continue examining the eligibility of
corporations having UPEs in Vietnam for application of global minimum tax, and
directly work with enterprises to complete the report according to the Global
Minimum Tax Impact Assessment Sheet in the Appendix enclosed herewith.
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General Department of Taxation attaches a Draft
Resolution on application of top-up tax according to regulations on global
anti-base erosion (planned to be effective from the fiscal year of 2024) and
the Open Letter about application of the Resolution.
Departments of Taxation shall send the Open Letter
to corporations and enterprises under their management which are potentially
regulated by the Resolution for dissemination purpose, and cooperate with
enterprises in assessing the impacts of regulations on global minimum tax as
well as preparing for the entry into force of the Resolution.
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For your information and compliance./.
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PP GENERAL
DIRECTOR
DEPUTY GENERAL DIRECTOR
Dang Ngoc Minh
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(Applicable to
multinational corporations having ultimate parent entities in Vietnam)
PART I. GENERAL INFORMATION
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2. Tax period: from ........... to
..........
3. Name of the ultimate parent entity (UPE):
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5. Revenue on consolidated financial statements
of the UPE:
- 2019:
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- 2021:
- 2022:
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(Unit: million VND)
No.
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Name of constituent entity (CE)
Pre-tax income on 2022's financial statements of the
CEs
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Total income or loss in 2022 of the corporation in
each country
Total tax payable in 2022 of the corporation in each
country
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Average income or loss of the corporation in each
country
Exeptions due to low revenue and income
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Top-up tax percentage
Total salaries according to 2022's financial
statements of the CEs in each country
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Value of tangible assets and deductible salaries
Profit subject to top-up tax
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Top-up tax of each CE
Ratio of distribution to UPE by CEs
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(6)
(7)
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(9)
(10)
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(12)
(13)
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(15)
(16)= (12)/ (11)
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(18)
(19)
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(21)=(11) -(20)
(22)=(21)* (17)
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(24)
(25)=(23)* (24)
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Vietnam
A
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B
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C
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Specify each
receiving country. e.g. Cambodia, Singapore
D
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E
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F
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G
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H
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I
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(8) The CEs listed in the sheet shall be those
included in the consolidated financial statement of the UPE and those excluded
from the consolidated financial statement on size or materiality grounds, or on
the grounds that the CEs are held for sale.
(11) Total income or loss in 2022 of the
corporation in each country = income in 2022 of all profitable CEs in a country
– Loss in 2022 of all loss-making CEs in the same country.
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Where: revenue in a country is the total revenue of
the CEs in such country.
(14) Average income or loss of the
corporation in each country = Average income or loss of 3 years (2020,
2021,2022) in the same country.
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(15) Top-up tax in a country is 0 if the
corporation satisfies both conditions below:
- The average revenue is under 260 billion VND
(equivalent to 10 million Euro)
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(22) Top-up tax of CEs shall be determined for
every CE that generates income in the fiscal year.
(24) Ratio of distribution to UPE by CEs = (Total
income of CEs – Income distributed according to holdings of other owners)/Income
of CEs
