E-Commerce Tax Administration, Basel III Banking Reforms, and Global Minimum Tax Implementation in Vietnam

Taxing online sales: Tightening Tax Administration for E-Commerce

Vietnam’s booming e-commerce market is bringing new opportunities for small businesses and individuals. Yet, questions arise about how to make sure everyone pays their fair share of relevant taxes. To address this fundamental issue, the government issued Decree 117/2025/ND-CP (“D.117”), taking effect on 1 June 2025.

The new decree sets out how taxes are collected from households and individuals selling goods and services through e-commerce and digital platforms such as online marketplaces, mobile apps, or websites.

D.117 shows Vietnam’s determination to keep up with the global digital economy and ensure everyone contributes fairly. The decree pushes platforms into a more active role in tax administration while increasing the compliance burden on small sellers.

Businesses operating in the e-commerce/digital space should begin preparing immediately to review their seller onboarding processes, accounting and record-keeping systems, and ensure compliance with withholding, declaration, and refund rules to avoid penalties

Read more

Contributed by Luther Vietnam Law LL.C.

Banking regulations aligned with Basel III

Vietnam’s banking sector takes another step towards global best practice as the State Bank of Vietnam (SBV) adopts Basel III principles through its new Circular 14/2025/TT-NHNN, effective 30 June 2025.

Replacing the 2016 regulation, the new circular strengthens capital adequacy, risk management, and transparency, key elements in ensuring financial stability and investor confidence.

By tightening criteria for regulatory capital, redefining risk-weighted assets, and improving collateral standards, the SBV aims to build a stronger, more resilient banking system aligned with international norms.

Circular 14 marks a decisive move from compliance-based supervision to a risk-focused, prudential approach, paving the way for a more sustainable and globally integrated financial sector.

Read more

Contributed by Luther Vietnam Law LL.C.

Application of Top-Up Tax in Vietnam

On 29 August 2025, the Government issued Decree No. 236/2025/ND-CP, effective from 15 October 2025, to implement the OECD’s Pillar Two/GloBE global minimum tax (“GMT”) in Vietnam.

The GMT applies to multinational enterprises (“MNE”) with consolidated global revenue of at least EUR 750 million in two or more of the four preceding fiscal years, and with constituent entities (“CE”) in Vietnam. A minimum effective tax rate (“ETR”) of 15% is required in each jurisdiction. Where the ETR in Vietnam is below 15%, a top-up tax will apply.

Each qualifying MNE must designate a CE in Vietnam as the Filing Entity, responsible for compliance with the Qualified Domestic Minimum Top-Up Tax (“QDMTT”) regime and obtain a specific tax identification number. The top-up tax return must be filed within 12 months after the end of the Ultimate Parent Entity’s (“UPE”) fiscal year. For FY2024, the Group Information Return and the Income Inclusion Return must be filed within 18 months after the UPE’s fiscal year-end, and within 15 months thereafter from FY2025 onwards.

For the first reporting year (FY2024), MNE whose fiscal year ends on or before 30 June 2025 must register the Filing Entity within 90 days from 15 October 2025.

Contributed by RBA WTS Vietnam

Subscribe "Law & Taxes Vietnam" on LinkedIn or via email to receive the next releases!