The Global Anti-Base
Erosion (GloBE) Rules took effect in 2024 and consequently posed significant
challenges to Vietnam’s traditional reliance on tax incentives for attracting
foreign investment. The country is responding to the Pillar two regime with
strategy and adaptation as well as initiating legal innovations to preserve its
tax sovereignty and maintain its competitive investments. This article argues
that Vietnam can adapt to the GloBE Rules while keeping its appeal to foreign
investors by reforming its legal frameworks and enhancing non-tax advantages.
This contribution explores how it can reconcile global minimum tax (GMT)
requirements with its strategic economic objectives by examining historical
practices, recent policy changes, and potential future implications.