Global Minimum Tax Advisory
Compliance – Optimization – Sustainability
Services
General Description of the Service
Crowe Vietnam’s Global Minimum Tax (GMT) Advisory Services are designed around three core objectives: Timely compliance - ensuring that enterprises fully comply with their QDMTT/IIR filing and tax payment obligations under Resolution No. 107 and relevant implementing regulations; Financial risk management - identifying and mitigating potential top-up tax liabilities arising from a low ETR, while avoiding late payment interest and penalties for incorrect tax filings; and Optimisation of long-term investment benefits - restructuring incentives and business models to maintain after-tax competitiveness and transform GMT-related challenges into sustainable strategic opportunities.
We provide Global Minimum Tax (GMT) Advisory Services through five flexible service packages tailored to the specific needs and readiness of each enterprise.
- Impact assessment & initial review: Analyse the group structure, existing tax incentives and preliminary top-up tax exposure to help enterprises understand whether they fall within the scope of GMT and identify the associated risks and opportunities.
- Data model & compliance process design: Develop data frameworks, templates, internal coordination procedures and processes for working with the parent group to ensure that GMT calculations and reporting are performed consistently and under appropriate controls.
- Annual GMT calculation and filing: Support enterprises in preparing GloBE calculations, determining the ETR and top-up tax, and preparing the relevant tax returns, appendices and supporting explanations in accordance with applicable regulations.
- Strategic advisory & incentive restructuring: Reassess the effectiveness of existing tax incentives in the context of GMT and recommend adjustments to investment structures, business models and non-tax support measures to optimise overall after-tax benefits.
- Training & internal support: Provide in-depth GMT training for finance and tax teams, develop internal guidance and data checklists, and provide ongoing support throughout the implementation process.
Service Context
Global Minimum Tax rules under Pillar Two are being implemented in many jurisdictions, including Vietnam, creating new requirements for effective tax rate calculations, data reporting and the determination of top-up tax liabilities for multinational enterprise groups. These changes may significantly affect the effectiveness of existing tax incentives, investment structures and enterprises’ overall tax obligations.
Global Minimum Tax Advisory Services are commonly required in the following circumstances:
- Enterprises within the scope of GMT: A company in Vietnam is a constituent entity of a multinational enterprise (MNE) group with consolidated revenue of EUR 750 million or more and needs to assess its effective tax rate (ETR) and potential top-up tax exposure.
- FDI enterprises benefiting from tax incentives or having a low ETR: An assessment is required to determine the impact of GMT on existing tax incentives and potential top-up tax liabilities.
- Enterprises preparing for GMT compliance: Processes need to be established for data collection, GloBE calculations, and the preparation of required documentation and tax filings.
- Enterprises undertaking investments or business restructuring: Investment structures and the effectiveness of tax incentives need to be reassessed in the context of GMT implementation.
Service delivery process and timeline
Service process
- Collect basic information on the group and the entity in Vietnam, including the group’s consolidated revenue, legal entity structure, jurisdiction of the Ultimate Parent Entity (UPE), existing tax incentives and current effective tax rate.
- Assess whether the enterprise is likely to fall within the scope of GMT and recommend an appropriate service scope, such as an impact assessment, compliance support or a comprehensive advisory package.
- Collect and analyse the enterprise’s financial and tax data for the past two to three years, including financial statements, CIT returns and information on tax incentives.
- Perform preliminary calculations of key indicators under the GloBE framework, including GloBE income, covered taxes and ETR, to assess the potential exposure to top-up tax in Vietnam.
- Prepare a GMT impact assessment report together with initial recommendations on data, systems and the compliance roadmap.
- Standardise and map accounting data from the existing system, whether under VAS or IFRS, to the data points required for GMT calculations.
- Advise on the development of processes for collecting, controlling and reporting GMT data between the entity in Vietnam and the group tax function, including data templates, reconciliation mechanisms and allocation of responsibilities among relevant departments.
- Perform GMT compliance procedures, including calculating GloBE income, determining the effective tax rate and top-up tax liabilities under the QDMTT/IIR mechanisms, and preparing the required documentation and tax returns.
- Prepare supporting explanations and coordinate with the tax authorities where requests arise in connection with GMT filings or tax audits.
- Continue supporting the enterprise in reviewing the effectiveness of existing tax incentives in the context of GMT and assessing potential adjustments to the investment structure or value chain to optimise after-tax benefits.
- Provide training for the enterprise’s finance and tax teams, update them on policy developments, and support the continuous enhancement of the enterprise’s GMT governance framework over the long term.
Timeline for service delivery
The service delivery timeline depends on the size of the group, the number of constituent entities, data readiness and the scope of support required. The estimated implementation timeline is typically as follows:
- Initial assessment and scope definition: 1 - 2 weeks
- Data analysis and impact assessment: 3 - 6 weeks
- Strategic advisory and recommended solutions: 2 - 3 weeks
- Implementation and compliance support: 2 - 4 weeks, depending on the scope of support
The overall timeline for impact assessment and basic advisory services is typically around 8 - 12 weeks and may be adjusted flexibly based on the enterprise’s specific needs and the client’s data submission timeline.
Quotation process and service fees
To prepare and send you a tailored quotation, we kindly request that you provide relevant information via our form and/or through an in-depth discussion. Based on the information collected, Crowe Vietnam will analyze your needs and specific requirements in order to:
- Assess the feasibility of service delivery: Determine whether we can provide the requested service appropriately and at a guaranteed quality level.
- Advise on optimal solutions: Recommend alternative solutions (if any) to help optimize efficiency and cost-effectiveness for your organization.
If we are able to support you, we will propose a reasonable fee based on:
- An estimated workload of the engagement;
- The level of professional expertise required from our team.
Estimated response time: The quotation process will be completed within 12 to 24 hours upon receiving your request.
Frequently asked questions
Is my enterprise subject to the Global Minimum Tax (GMT)?
Crowe Vietnam can assist in reviewing the group structure, consolidated revenue and other relevant factors to determine whether the enterprise falls within the scope of GMT under the prevailing regulations.
How will GMT affect the enterprise’s tax incentives and tax obligations in Vietnam?
Global Minimum Tax (GMT) Advisory Services help assess the enterprise’s effective tax rate (ETR), identify potential top-up tax liabilities, and analyse the extent to which GMT may affect its existing tax incentives.
What data does the enterprise need to prepare for a GMT assessment?
Clients are generally required to provide consolidated financial data, tax information of entities within the group, and other relevant data required for the calculation of the ETR and top-up tax liabilities. Crowe Vietnam will provide detailed guidance on the list of data to be prepared.
Does Crowe Vietnam support top-up tax calculations and the preparation of reports required under GMT regulations?
We support enterprises throughout the process, from calculating top-up tax and developing tax liability forecasting models to preparing the required documentation and reports, as well as providing support with explanations when necessary.
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Crowe Vietnam is committed to delivering high quality solutions and services at reasonable costs, ensuring an exceptional client experience. We consistently strive for differentiation and continuously enhance the professional capabilities of our team to best meet the evolving needs of our clients.
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Why choose us for this service?
Choosing the right service partner is a key factor in ensuring both effectiveness and peace of mind. Here’s why Crowe Vietnam is the trusted choice for you.
International Brand
Crowe Vietnam is a full member of Crowe Global, a top 10 global network of audit, accounting, tax and advisory firms operating in 150 countries. Our international brand enables us to deliver high-quality audit services in accordance with international standards, helping clients enhance their credibility in the marketplace.
Assured Expertise
With a team of experienced professionals holding internationally recognised qualifications such as ACCA, CPA, ICAEW and CA ANZ, Crowe Vietnam is committed to delivering audit and assurance services of high professional quality, fully aligned with both international and Vietnamese auditing standards.
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Through our extensive connection with the Crowe Global network, Crowe Vietnam is always ready to help clients access international professionals and seconded personnel, providing comprehensive advisory and support to address complex issues in today’s global business environment.
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Crowe Vietnam is committed to delivering high-quality audit solutions at reasonable fees, helping clients optimise costs. We continuously strive to improve and enhance operational efficiency, enabling clients to achieve maximum value within an appropriate budget.
Senior Personnel
Nam Nguyen
Chairman & Managing PartnerFCPA, CTA, FCCA
Lam Vu
General Director & Audit DirectorCPA VN, CPA AU, CTA, MA
Linh Nguyen
Partner, Tax & AdvisoryCPA VN, CPA Aust., CTA
Phat Tran
Partner, Audit & AssuranceFCCA, CIA, CPA VN, CTA