On January 22nd, 2025, the General Department of Taxation issued Official Letter No. 372/TCT-CS, accordingly:
In case the constituent units in Vietnam of a multinational corporation subject to the global minimum tax regulations meet the conditions for corporate income tax incentives, they will continue to enjoy corporate income tax incentives according to the current corporate income tax regulations. However, based on Articles 2 and 4 of Resolution No. 107/2023/QH15, after applying the incentives, if the effective tax rate of the corporation in Vietnam is below the 15% minimum tax rate, additional corporate income tax must be paid according to the global minimum tax regulations.