With the ratification of Resolution no. 107/2023/QH15 (“Resolution 107”) in 2023 and its having come into effect on 1 January 2024, the National Assembly has enacted an add-on corporate income tax (“CIT”) that some multinationals that have received a tax holiday will nevertheless have to pay. This is in line with the Global Anti-Base Erosion (GloBE) Model Rules. GLoBE is focused on companies that invest large sums in a country and so qualify for a partial or total CIT holiday, thereby sometimes paying little or no CIT for a fixed number of years. The GloBE’s objective is to guarantee that corporations pay a minimum income tax in each country that adopts GLoBE rules. There is a simple background for the GLoBE concept. Competition for investors has encouraged countries to compete by reducing the corporate income tax investors pay. Often the incentives are quite large. This has seriously reduced tax revenues in many countries.