Nearly 200 Foreign Direct Investment Enterprises in Vietnam Subject to Minimum Global Tax Obligations

The implementation of global minimum tax regulations in Vietnam has entered a critical operational phase, shedding light on the precise number of multinational corporations that fall within the scope of this landmark international tax framework. According to recent announcements by senior tax authorities, out of an estimated 45,000 foreign direct investment (FDI) projects currently operating across Vietnam, approximately 1,500 projects meet the revenue threshold required to be subject to the global minimum tax regime. Among these high-revenue multinational entities, nearly 200 enterprises have officially generated tax liabilities under the new rules, marking a significant evolution in how Vietnam collects revenue from international corporations.

The disclosure was made by Dang Ngoc Minh, Deputy Director General of the General Department of Taxation, during a specialized seminar on tax policies concerning foreign-invested enterprises. The event, organized by the General Department of Taxation, brought together key policymakers, economic experts, and international representatives to discuss the profound structural changes taking place within Vietnam’s investment and tax landscapes.

Background and Framework of the Global Minimum Tax in Vietnam

The global minimum tax framework, formally known as Pillar Two of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), establishes a mandatory 15% effective tax rate for large multinational enterprises with annual global revenues exceeding 750 million euros. For decades, Vietnam—like many developing economies—has successfully attracted massive inflows of foreign capital by offering highly competitive investment incentives, including preferential corporate income tax rates as low as 5%, 10%, or extended tax holidays.

However, with the advent of the global minimum tax agreement, multinational corporations headquartered elsewhere could find themselves facing top-up taxes in their home jurisdictions if the effective tax rate paid in host countries like Vietnam falls below the 15% minimum. To protect its national taxing rights and retain revenues that would otherwise be remitted abroad, Vietnam enacted and implemented the global minimum tax policy, ensuring that qualifying enterprises pay the 15% rate directly to the national budget.

According to tax authorities, the implementation of these rules is projected to generate substantial fiscal resources for the country. Total state revenues derived from the global minimum tax are estimated to reach approximately VND 16,500 billion for the 2025 fiscal year. This financial inflow not only provides critical funding for socioeconomic development projects and public infrastructure but also effectively reclaims a portion of the tax incentives previously forgone to attract early-stage investments.

Shifting Paradigms: Beyond Capital Influx to Quality and Sustainability

The introduction of the global minimum tax coincides with a broader strategic pivot in Vietnam’s economic development model. Mai Xuan Thanh, Director General of the General Department of Taxation, emphasized at the seminar that after nearly 40 years of welcoming foreign investment, the FDI sector has firmly established itself as an indispensable pillar of the Vietnamese economy. It has served as a primary driver for rapid economic growth, export expansion, employment generation, and technological transfer.

Nevertheless, as Vietnam transitions into a new phase of developmental maturity, the national economic strategy is shifting away from a sheer focus on the volume of registered capital toward the quality, efficiency, and long-term sustainability of incoming capital flows. Policymakers are placing heightened emphasis on the value added by foreign enterprises and their contributions to the country’s independent economic resilience.

Echoing this perspective, Nguyen Anh Tuan, Deputy Director General of the Foreign Investment Agency under the Ministry of Finance, noted that Vietnam is actively striving to elevate its productivity, growth quality, national competitiveness, and economic self-reliance. While continuing to court foreign capital remains a policy priority, the paramount objective is now to deepen the integration between the FDI sector and domestic industrial capacities, aligning foreign projects with the nation’s long-term strategic goals.

International stakeholders have closely monitored these regulatory shifts. Roux Eloise, a representative of the European Union Delegation to Vietnam, praised the country as a long-standing and trusted partner of the EU, highlighting their increasingly robust bilateral economic ties. Eloise pointed to Vietnam’s strong economic absorption capacity, rapidly expanding domestic market, robust infrastructure, sophisticated logistics network, and expansive web of free trade agreements as key competitive advantages.

Data highlights the strength of this partnership, noting that foreign direct investment into Vietnam reached historic highs through 2025 and into the early quarters of 2026. Cumulative FDI from EU member states alone reached approximately $30.5 billion by the close of 2025, underscoring deep investor confidence despite the introduction of stricter global tax standards.

Redesigning Investment Incentives: From Tax Reductions to Cost Support

With the implementation of the global minimum tax eroding the attractiveness of traditional tax holiday incentives, Vietnam is fundamentally redesigning its incentive architecture. Deputy Director General Dang Ngoc Minh stated that investment attraction can no longer rely primarily on preferential tax rates linked to corporate income. Instead, the national strategy is transitioning toward direct cost-support mechanisms.

Under the forthcoming policy framework, state support will pivot toward areas such as technology grants, research and development subsidies, technology transfer promotion, and specialized workforce training tailored for high-tech industries. Furthermore, the Vietnamese government is heavily investing in industrial infrastructure to help foreign and domestic enterprises build integrated ecosystems.

To achieve this, future incentives will increasingly be tied to the tangible outputs and performance metrics of enterprises—specifically focusing on successful technology transfer, local workforce upskilling, and integration with domestic supply chains. Minh emphasized that these commitments and the corresponding incentive packages must be explicitly publicized from the outset and clearly stipulated in the investment registration certificates issued to enterprises.

Enhanced Monitoring and Compliance Architecture

To ensure that multinational corporations fulfill their developmental and technological commitments under the new incentive regime, the Vietnamese tax administration is establishing a rigorous, modern monitoring framework.

Rather than relying on intrusive, traditional auditing methods that place administrative burdens on compliant businesses, the General Department of Taxation is constructing a centralized, shared-data digital infrastructure. This platform will integrate database systems concerning corporate operations, tax filings, and demographic registries, enabling seamless coordination across various departments within the Ministry of Finance and broader governmental agencies.

Under this streamlined architecture, enterprises will be required to submit structured information and formal commitments electronically. Tax authorities will then conduct indirect monitoring and post-audits based on performance evaluations and data analytics. This modern approach aims to reduce compliance costs for high-performing multinational corporations while maintaining stringent oversight to guarantee that foreign investments genuinely contribute to Vietnam’s sustainable, high-tech economic future.