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More than 65 jurisdictions now apply or are adopting a 15% minimum tax on large groups. What it changes – and what it doesn't – for Vietnamese family businesses.
The global minimum tax – the OECD's Pillar Two – requires multinational groups with consolidated revenue of EUR 750 million or more to pay an effective tax rate of at least 15% in every jurisdiction where they operate. According to the OECD Secretary-General's April 2026 report to the G20, more than 65 jurisdictions have implemented the rules or are in the process of doing so, including the EU, the UK, Japan, South Korea, Vietnam and the UAE. For big groups, the era of the zero-tax haven is ending. For individuals and most family businesses, the rules barely change – and understanding that boundary matters more than any rumour.
Source: OECD Secretary-General Tax Report to the G20 (April 2026); OECD Taxation Working Paper No. 68 (2024); PwC Worldwide Tax Summaries
Mention the "global minimum tax" and many Vietnamese business owners worry that every tax advantage in Dubai, Cyprus or Singapore is about to vanish, and that setting up or investing abroad no longer makes sense. The reality is far more nuanced. Pillar Two targets a narrow group – very large groups – and taxes corporate profit, not personal income or wealth.
Using four charts and a timeline table, this piece answers three questions: how far the rules have spread, how much they raise, and who they actually touch.
From the 2021 Deal to More Than 65 Jurisdictions
On 8 October 2021, 137 countries and jurisdictions in the OECD/G20 Inclusive Framework signed up to the two-pillar solution. Pillar Two sets a floor: if a group's effective tax rate in a country falls below 15%, the shortfall is topped up – first by that country through a qualified domestic minimum top-up tax (QDMTT), then by the parent company's country (the IIR), and finally by other countries where the group operates (the UTPR).
Topping up at home has become the default. Rather than let another country collect the top-up, many jurisdictions now levy their own domestic minimum tax. According to the OECD Secretary-General's report of April 2026, more than 65 jurisdictions have implemented, or are implementing, the GloBE rules or a QDMTT.
| Jurisdiction | Mechanism | In force |
|---|---|---|
| European Union | Directive 2022/2523: IIR, UTPR, QDMTT | From end-2023, via national laws |
| Vietnam | Domestic minimum top-up tax and IIR | National Assembly resolution of 29 Nov 2023, applying from 1 Jan 2024 |
| South Korea | IIR, then UTPR | IIR from 2024, UTPR from 2025 |
| Japan | IIR | Fiscal years starting on or after 1 April 2024 |
| Türkiye | IIR, QDMTT, then UTPR | 2024, UTPR from 2025 |
| UAE | Domestic minimum top-up tax (DMTT) | Fiscal years starting on or after 1 Jan 2025 |
| Singapore, Malaysia, Thailand, Hong Kong | IIR and domestic minimum tax | From 2025 |
| United States | Not adopted; recognised under a "side-by-side" regime | From 1 Jan 2026 |
America Stepped Out – but Not Entirely
In January 2025 the Trump administration declared that US commitments under the global deal had no force without Congressional approval. After months of negotiation, on 5 January 2026 the 147-member Inclusive Framework published a "Side-by-Side" package. As EY's analysis explains, US-parented groups can elect out of the IIR and UTPR because the US already runs its own minimum tax system.
The detail matters. The package confirms that domestic minimum top-up taxes still apply to every group, US groups included. In other words, a subsidiary of an American group in Dubai or Hanoi still has to pay the full 15% locally if that country has a QDMTT. The deal survived, but its centre of gravity shifted towards the countries that host investment.
Bermuda, once a byword for zero tax, now applies 15% to businesses within the scope of its new corporate income tax.
Headline Rates: Several Countries Have Moved
Pillar Two works on effective tax rates, not headline rates. Even so, headline rates reveal the pressure the rules create. Cyprus raised its corporate tax rate from 12.5% to 15% from 1 January 2026. Bermuda, once a byword for zero tax, now applies 15% to businesses within the scope of its new corporate income tax.
The UAE's 9% doesn't mean large groups pay 9%. According to PwC, the UAE has applied a domestic minimum top-up tax since fiscal year 2025 to groups above the EUR 750 million threshold, so the gap up to 15% is collected in the UAE. For businesses below the threshold, the 9% rate – and 0% on taxable income up to AED 375,000 – is unchanged.
Vietnam feels the pressure from another angle. The issue isn't its 20% headline rate but the tax holidays and reductions it has long used to attract foreign investment. When incentives push a large group's effective rate below 15%, the gap is topped up, so the incentive loses much of its pull. Vietnam's new Corporate Income Tax Law, effective from 1 October 2025, has also reshaped the incentive regime significantly.
What Does the World Collect?
According to the OECD's updated estimate published in January 2024 and based on 2017–2020 data, the global minimum tax could raise an extra USD 155–192 billion a year, an increase of 6.5–8.1% in global corporate income tax revenue. Around two-thirds comes directly from top-up tax and one-third from groups shifting less profit.
View data table
| Item | Value |
|---|---|
| Global – low | 6.5% |
| Global – high | 8.1% |
| Developed – low | 5.1% |
| Developed – high | 8% |
| Developing – low | 3.6% |
| Developing – high | 7.8% |
Source: OECD (2024), The Global Minimum Tax and the taxation of MNE profit, OECD Taxation Working Papers No. 68
Low-taxed profit is set to shrink sharply. The OECD also estimates that about 36% of global multinational profit is taxed at an effective rate below 15%; Pillar Two is expected to cut that to around 7%. In investment hubs, 74% of profit is low-taxed – the group that feels the biggest impact.
Treat these numbers with care. They are estimates based on pre-implementation data and assume near-universal adoption. The US carve-out from the IIR and UTPR under the side-by-side package, together with new safe harbours, could leave actual revenue below the original estimate.
What It Means for Individuals and Family Businesses
It doesn't apply to personal income tax. Pillar Two taxes only the profits of groups above the threshold. The UAE still levies no personal income tax, and new-resident regimes in Greece or Italy fall outside these rules.
Over time, countries will compete more on infrastructure, talent and legal stability than on tax rates.
Most family businesses sit below the threshold. EUR 750 million of consolidated revenue is a very large number. A small Cypriot holding company or a Dubai trading business owned by a Vietnamese family is usually out of scope. One caveat: some jurisdictions, including EU members, also apply the rules to large domestic groups, so size – not nationality – is the test.
Tax incentives for big groups will lose their shine. A multinational's factory in Vietnam or Malaysia no longer keeps the full benefit of a tax holiday. Over time, countries will compete more on infrastructure, talent and legal stability than on tax rates.
A practical strategy for Vietnamese investors
Check whether you are in scope. If your family group's consolidated revenue is below EUR 750 million, Pillar Two barely touches you. Don't let rumours push you into restructuring you don't need.
Separate corporate tax from personal tax. The reasons to hold residence or property in Dubai or Cyprus are mostly about personal tax, residence rights and quality of life – none of which Pillar Two changes.
Watch the knock-on changes. Cyprus raised its corporate rate to 15%; Vietnam rewrote its incentive law. Each change can indirectly affect a holding company or investment plan, so review your set-up regularly.
Prioritise stability over the lowest rate. As tax gaps narrow, places with clear law and stable residence programmes – Kuala Lumpur or Athens, for example – become more valuable.
Frequently asked questions
Does the global minimum tax apply to individuals?
No. Pillar Two applies only to the profits of groups with consolidated revenue of EUR 750 million or more. Personal income tax, inheritance tax and wealth taxes are outside its scope.
When did Vietnam adopt the global minimum tax?
The National Assembly passed its resolution on the global minimum tax on 29 November 2023, applying from 1 January 2024, with a domestic minimum top-up tax and an IIR. The top-up tax goes to the central state budget.
Is this tax advice?
No. This is a summary of public information for reference only. Pillar Two rules are evolving quickly and depend on each group's structure, so please consult a licensed tax professional before making decisions.
NAC strategic insight
The global minimum tax closes an era for large groups: nowhere will let vast profits be taxed at close to zero any more. For Vietnamese families, it also clarifies something important – the case for international assets and residence was never only about corporate tax. It is about diversifying legal systems, currencies and places to live for the next generation.
NAC helps families separate what has genuinely changed from what is just noise, then choose markets and programmes that fit their long-term plans. If you'd like to review your family's international structure, book a consultation with NAC.
Sources
- OECD — Secretary-General Tax Report to G20 Finance Ministers, April 2026 (2026)
- EY — OECD releases Side-by-Side package on Pillar Two global minimum tax (2026)
- OECD — The Global Minimum Tax and the taxation of MNE profit, Working Paper No. 68 (2024)
- PwC — Worldwide Tax Summaries: Vietnam, Corporate – Significant developments (2026)
- PwC — Worldwide Tax Summaries: Corporate income tax rates (2026)
