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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:
- Departments of Taxation of provinces and
centrally affiliated cities;
- Major Enterprise Department of Taxation
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.
In case any of the 64 corporations on the List
enclosed with Official Dispatch No. 1939/TCT-CS dated 19/5/2023 is found to be
ineligible for application of global minimum tax, the Departments of Taxation
must report and provide explanation.
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.
Reports shall be sent both in writing to General
Department of Taxation at 123 Lo Duc street, Hai Ba Trung district, Hanoi and
by email to [email protected] before 16/11/2023.
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PP GENERAL
DIRECTOR
DEPUTY GENERAL DIRECTOR
Dang Ngoc Minh
GLOBAL MINIMUM
TAX IMPACT ASSESSMENT SHEET
(Applicable to
multinational corporations having ultimate parent entities in Vietnam)
PART I. GENERAL INFORMATION
1. Name of multinational corporation:
2. Tax period: from ........... to
..........
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4.
TIN of the UPE:
5. Revenue on consolidated financial statements
of the UPE:
- 2019:
- 2020:
- 2021:
- 2022:
PART 2. IMPACT ASSESSMENT
(Unit: million VND)
No.
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Name of constituent entity (CE)
Pre-tax income on 2022's financial statements of the
CEs
Total pre-tax income on 2022's financial statement s
of the CEs in each country
Total income or loss in 2022 of the corporation in
each country
Total tax payable in 2022 of the corporation in each
country
Average revenue of the corporation in each country
Average income or loss of the corporation in each
country
Exeptions due to low revenue and income
Actual tax rate of the corporation in each country
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Total salaries according to 2022's financial
statements of the CEs in each country
Total value of tangible assets (after depreciation) according
to 2022's financial statements of the CEs in each country
Value of tangible assets and deductible salaries
Profit subject to top-up tax
Total top-up tax in a country
Top-up tax of each CE
Ratio of distribution to UPE by CEs
Top-up tax distributed to UPE
(6)
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(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)= (12)/ (11)
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(18)
(19)
(20)= 10%*(18) +8%*(19)
(21)=(11) -(20)
(22)=(21)* (17)
(23)=(22)*(9) /(10)
(24)
(25)=(23)* (24)
1
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A
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B
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C
2
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D
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E
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F
3
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G
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H
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I
(7) Arrange by country in which the entities
affiliated to the corporation invest.
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(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.
(13) Average revenue of the corporation in
each country – average revenue of 3 years ((2020, 2021, 2022) in the same
country.
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.
Where: Income or loss in a country is the total income
or loss of the CEs in such country.
(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)
- The average pre-tax income is under 26 billion
VND (equivalent to 1 million Euro)
(22) Top-up tax of CEs shall be determined for
every CE that generates income in the fiscal year.
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