Investment incentives in Vietnam go to projects in a preferential sector, in a preferential location, or of a qualifying size, workforce or national importance (Article 14(1) of the Law on Investment 143/2025/QH15). They take the form of corporate income tax (CIT) incentives, import duty exemptions, exemption or reduction of land levy, land rent and land use tax, and accelerated depreciation or higher deductible expenses (Article 14(2)). They apply only to new and expansion projects, they are time-limited and performance-based, and the investor must keep meeting the conditions for as long as it claims them (Article 14(5) and (8)).
The point most foreign investors miss: the Law on Investment only tells you whether a project is eligible. The actual rate or amount comes from the tax, accounting and land laws (Article 14(6)), and the CIT law uses narrower sector and location lists than the investment law. A factory in an industrial park can be an "incentivised project" for investment purposes and still get no CIT incentive at all. This note reflects the law in force as of 14 October 2026: the Law on Investment 143 (in force from 1 March 2026), Decree 96/2026/ND-CP, the Law on Corporate Income Tax 67/2025/QH15 (Consolidated Text 113/VBHN-VPQH) and Decree 320/2025/ND-CP.
What investment incentives in Vietnam cover#
Investment incentives in Vietnam come in five forms, each applied by a different authority under its own law:
| Form (Article 14(2)) | Law that sets the amount | Authority applying it |
|---|---|---|
| Lower CIT rate, CIT exemption or reduction | Law 67/2025 on CIT, Decree 320/2025 | Tax authority |
| Import duty exemption for goods forming fixed assets, and for materials and components used in production | Import and export duty law | Customs |
| Exemption or reduction of land levy, land rent and land use tax | Land law | Land and tax authorities |
| Accelerated depreciation, higher deductible expenses | Tax and accounting law | Tax authority |
| Other forms | Government regulations | Depends on the form |
Decree 96 adds one that is easy to overlook: where a project must post a performance deposit, the deposit is cut by 25% for a preferential sector or a disadvantaged location, and by 50% for a specially preferential sector, an extremely disadvantaged location, or a preferential sector in a disadvantaged location. The three project types excluded by Article 14(7) of the Law on Investment (listed below) get no reduction (Article 27(4)).
Three general rules apply across the board:
- No stacking. A project that qualifies under several headings gets the most favourable one (Article 14(9) of the Law on Investment; Article 20(5) of Decree 96). The CIT law likewise lets the company choose the most favourable incentive for the same income (Article 12(1) of Law 67).
- Location incentives exclude three project types: mining; goods or services subject to special consumption tax (other than manufacturing cars, aircraft and yachts); and commercial housing (Article 14(7)). The clause refers only to point (b) of Article 14(1), the location route; the same three types are also shut out of special incentives (Article 17(5)(b)). The CIT law has its own, wider exclusion: income from mining and from goods and services subject to special consumption tax gets no CIT incentive on either sector or location grounds (Article 18(3) of Law 67).
- Protection against adverse change. If a new law offers more, the investor gets the new level for the rest of the period; if it offers less, the investor keeps the old level, except where the change is made for defence, national security, public order, social morality, public health or the environment (Article 12(1) to (3)). The protection covers incentives that are not written on any licence as well (Article 4(2) of Decree 96).
Three routes to investment incentives in Vietnam#
Article 19 of Decree 96 lists 16 categories of projects eligible for investment incentives in Vietnam. In practice there are three routes.
Route 1: sector. Appendix II of Decree 96 has two tiers. Part A, specially preferential sectors: high and strategic technology, software, semiconductors, renewable energy, priority supporting industries, processing of farm, forest and aquatic products, industrial park infrastructure, pharmaceuticals and more. Part B, preferential sectors: R&D, cars and car parts, electronic components, products with 30% or more value added, digital technology services, logistics centres, supermarkets, private schools, medical devices, innovative start-ups and more.
Route 2: location. Since the two-tier local government reform, preferential locations are fixed at commune level (Article 22 of Decree 96). Extremely disadvantaged locations include communes in Zone II and Zone III of ethnic minority and mountainous areas and communes that belonged to extremely disadvantaged districts before the reorganisation; disadvantaged locations include Zone I communes and communes of former disadvantaged districts (Article 22(2) and (3)). The provincial People's Committee publishes the commune list (Article 22(8)). Decree 31/2021/ND-CP, including its Appendix III list of locations, ceased to have effect on 1 March 2026 (Article 111(3)(a)), so check the province's list rather than the old one.
Route 3: size and project type (Articles 19 and 20 of Decree 96):
| Project | Condition | Treated as |
|---|---|---|
| Capital of VND 6,000 billion or more (Article 19(3)) | At least VND 6,000 billion disbursed within 3 years of the IRC or approval; revenue of VND 10,000 billion a year or 3,000 average employees within 3 years of first revenue | Extremely disadvantaged location (Article 20(1)) |
| Rural project with 500 or more regular employees (Article 19(5)), or 30% or more employees with disabilities (Article 19(6)) | Part-time staff and contracts under 12 months do not count towards the 500 | Disadvantaged location (Article 20(2)) |
| Preferential sector in a disadvantaged location | Both conditions | Extremely disadvantaged location (Article 20(3)) |
High-tech and science and technology enterprises, R&D centres, innovative start-ups, social housing and several other categories are covered by Article 19(4) and (7) to (16).
Investment incentives in Vietnam for industrial park projects: why the CIT law differs#
The Law on Investment treats industrial parks, industrial clusters, export processing zones, economic zones, high-tech parks and free trade zones as preferential locations (Article 15(2)(b)). Decree 96 then grades them: economic zones, high-tech parks, hi-tech agricultural zones, digital technology parks, free trade zones and international financial centres get the incentives of an extremely disadvantaged location; an industrial park, industrial cluster or export processing zone gets those of a disadvantaged location (Article 22(7)).
The CIT law lists only three groups of tax-preferential locations: extremely disadvantaged areas; disadvantaged areas; and economic zones, high-tech parks, hi-tech agricultural zones and digital technology parks (Article 12(3) of Law 67). Industrial parks, clusters and export processing zones are not named, and where another law provides CIT incentives that differ from Law 67, Law 67 prevails (Article 12(1)). This is why an export processing enterprise gets no CIT incentive just for its location; its tax advantages lie in import duty and VAT.
Decree 320 excludes industrial parks in so many words. Article 18(3)(a) and (b) take extremely disadvantaged and disadvantaged areas "under the investment law", but carve out item 55 of Appendix III to Decree 31/2021/ND-CP. Item 55, as amended by Article 1(37) of Decree 239/2025/ND-CP, is the row that puts economic zones, high-tech parks and digital technology parks in the extremely disadvantaged column and industrial parks, export processing zones and industrial clusters in the disadvantaged column. Economic zones and the technology parks are brought back in point (c); industrial parks are not. Decree 31 has been repealed, but a reference to a replaced instrument is read as a reference to its replacement (Article 24(3) of Decree 320), which is Article 22(7) of Decree 96 with the same grading. Where another decree provides CIT incentives that differ from Decree 320, Decree 320 prevails (Article 18(1)). So the Decree 96 rule that an industrial park is treated like a disadvantaged location does not carry a CIT incentive with it.
The Ministry of Finance has answered the same way in its financial policy Q&A (question submitted on 2 April 2026): a new or expansion project in an industrial park that received its IRC or investment policy approval on or after 1 October 2025 gets no CIT incentive on location grounds; a project in an industrial park located in a disadvantaged or extremely disadvantaged area still gets the location incentive; and a project in a tax-preferential sector gets the sector incentive. The Tay Ninh tax office applied exactly this approach in Official Letter 8091/TNI-QLDN2 of 23 September 2026: a new project in an industrial cluster got 17% for 10 years, 2 years exempt and 50% off for 4 years because the commune where the cluster sits is a disadvantaged area on the province's published list. Neither document is a legal instrument, but both match the wording of Decree 320. For an industrial park in a commune that is not a preferential area, the remaining route is a tax-preferential sector.
Two other investment incentives in Vietnam still apply to industrial park projects under their own laws:
- Import duty. Goods imported to form the fixed assets (machinery, equipment, specialised transport, construction materials not made in Vietnam) of a project entitled to investment incentives under the investment law are exempt from import duty, for both new and expansion projects (Article 16(11) of the Law on Export and Import Duties 107/2016/QH13; Law 90/2025/QH15 did not amend this clause). An industrial park is a preferential investment location, so projects inside it qualify. The 5-year exemption for production materials and components (Article 16(13)) is narrower: it covers specially preferential sectors, extremely disadvantaged areas and certain high-tech and science and technology enterprises.
- Land rent. Land rent exemptions and reductions under Decree 103/2024/ND-CP apply only to the party leasing land directly from the State (Article 38(3)). A factory subleasing land from the industrial park developer pays rent under its contract with the developer and gets no exemption of its own. The list of preferential locations for land rent also counts only areas with defined administrative boundaries (Article 38(13), as amended by Decree 291/2025/ND-CP).
The sector lists diverge too. Appendix II of Decree 96 against Article 12(2) of Law 67:
| Project | Law on Investment | CIT law |
|---|---|---|
| Software production | Specially preferential (Part A.I.5) | Tax-preferential sector (point b): 10% for 15 years, 4 years exempt, 50% off for 9 years |
| Logistics centre, warehouse, supermarket | Preferential (Part B.III.5) | Not a tax-preferential sector; incentive only if located in a tax-preferential area |
| Garment factory in an industrial park in an ordinary commune | Preferential location (industrial park) | No location incentive; only a sector incentive if the product is in a tax-preferential sector (for example priority supporting industry products, point c) |
| Car manufacturing and assembly | Preferential (Part B.I.7) | Tax-preferential sector (point n): 17% for 10 years, 2 years exempt, 50% off for 4 years |
For trading and service projects in a tax-preferential area, only income generated in that area qualifies; a manufacturing project keeps the incentive on goods sold outside the area (Article 23(3) of Decree 320).
Corporate income tax incentives: rates and tax holidays#
Corporate income tax incentives are the part of investment incentives in Vietnam that investors usually model first. They have two layers that run together: a preferential rate for a set period (Article 13 of Law 67; Article 19 of Decree 320) and an exemption followed by a 50% reduction of tax payable (Article 14 of Law 67; Article 20 of Decree 320). The standard rate is 20% (Article 10(1)).
| New investment project | Rate | Holiday |
|---|---|---|
| Sectors in Article 12(2)(a) to (dd) (high technology, software, semiconductors, priority supporting industries, renewable energy, environmental protection, key infrastructure); group 2 high-tech enterprises and science and technology enterprises; manufacturing projects of VND 12,000 billion or more (point g); special incentive projects (point h); extremely disadvantaged areas; high-tech parks, hi-tech agricultural zones, digital technology parks; economic zones in preferential areas | 10% for 15 years (Article 13(1)) | Up to 4 years exempt, then 50% off for up to 9 years (Article 14(1)) |
| Strategic technology enterprises, group 1 high-tech enterprises, high-tech or strategic technology R&D centres (point e1) | 10% for 25 years (Article 13(1a)) | As above |
| Sectors in points m, n and o (high-grade steel, energy-saving products, farm machinery, animal feed, cars, other digital technology products, SME support facilities); disadvantaged areas; economic zones outside preferential areas; manufacturers of high-tech products (point e2) | 17% for 10 years (Article 13(4)) | Up to 2 years exempt, then 50% off for up to 4 years (Article 14(2)) |
| Socialised education, health, culture, sport and environment (point r); forestry, plant and animal breeding, post-harvest storage (point i); social housing (point s) | 10% for the life of the activity (Article 13(2); Article 19(2) of Decree 320) | Socialised activities: up to 4 years exempt and 50% off for up to 9 years in disadvantaged areas; elsewhere up to 4 years exempt and 50% off for up to 5 years (Article 14(1)(b)). Points i and s: Article 14 provides no holiday |
The 15% and 17% rates for companies with prior-year revenue up to VND 3 billion and VND 50 billion (Article 10(2) and (3)) are size-based rates, not investment incentives; see how to calculate corporate income tax in Vietnam.
When the clock starts. The preferential rate runs from the first year the new project has revenue (Article 13(7) of Law 67). The holiday runs from the first year of taxable income; if there is none in the first 3 years from first revenue, it starts in year 4 (Article 14(4)). Where a high-tech, science and technology or supporting industry certificate is issued after revenue or income has begun, the clock runs from the year the first certificate is issued.
Example: a foreign-owned software company receives its IRC in 2026, has revenue from 2027 and taxable income from 2029. The 10% rate applies from 2027 to 2041. 2029 falls within the first 3 years of revenue, so tax is exempt from 2029 to 2032 and halved from 2033 to 2041. If 2029 is still loss-making, the holiday starts in 2030.
Income that never qualifies, even inside an incentivised project (Article 18(3) of Law 67; Article 23(9) of Decree 320): gains on transfers of capital, real estate (other than social housing) and projects; income earned outside Vietnam; oil, gas and mining; online games; goods and services subject to special consumption tax (except cars, aircraft, yachts and oil refining); and other income unrelated to the incentivised activity. Incentivised income must be accounted for separately, failing which it is apportioned by revenue or cost (Article 18(2) of Law 67). Share sale gains follow their own rules, see CIT on capital transfers in Vietnam.
A company that switches to a more favourable criterion mid-way deducts the years already used and cannot switch back (Article 23(2) of Decree 320).
Special investment incentives: thresholds and tax effect#
Special investment incentives are the top tier of investment incentives in Vietnam and are reserved for three groups (Article 17(2) of the Law on Investment; Article 21(1) of Decree 96):
| Group | Capital and disbursement (counted from the IRC or investment policy approval) |
|---|---|
| New (including later expansion of) innovation centres, R&D centres, large data centre, cloud and 5G-or-higher infrastructure, and strategic technology projects designated by the Prime Minister | Total capital of VND 3,000 billion or more, at least VND 1,000 billion disbursed within 3 years |
| Key digital technology products; semiconductor R&D, design, fabrication, packaging and testing; AI data centres | Total capital of VND 6,000 billion or more, at least VND 6,000 billion disbursed within 5 years |
| New or expansion projects in specially preferential sectors | Capital of VND 30,000 billion or more, at least VND 10,000 billion disbursed within 3 years |
The National Innovation Centre established by the Prime Minister qualifies without a capital threshold (Article 21(3)). Pharmaceutical projects of VND 3,000 billion or more with VND 1,000 billion disbursed within 3 years are treated like the first group (Article 8(2) of the Pharmaceutical Law, as amended by Article 50(1) of the Law on Investment).
On the tax side, these are point h projects under Article 12(2) of Law 67. The Prime Minister may cut the 10% rate by up to half (so to 5%), for up to 1.5 times the normal period, extendable by up to 15 years but not beyond the project term (Article 13(6)(b)), and may extend the holiday to up to 1.5 times the normal length (Article 14(3)). The decision weighs technology, technology transfer, participation of Vietnamese suppliers and domestic value added (Article 21(5) of Decree 96). These enhanced levels need a Prime Minister decision; they cannot be self-assessed.
Three further points:
- They are not available to projects that obtained an investment certificate, IRC or investment policy decision before 1 March 2026 (Article 17(5)(a) of the Law on Investment).
- The investor must commit to the sector, total capital, disbursement amount and deadline and any other conditions written in the IRC or approval (Article 21(4) of Decree 96).
- A manufacturing project of VND 12,000 billion or more, fully disbursed within 5 years and using technology approved by the Ministry of Science and Technology, has its own route: 10% for 15 years under point g of Article 12(2) of Law 67.
Disbursement has two layers. Point h of Law 67 (as amended by Article 50(2) of the Law on Investment) leaves the disbursement period for total registered capital to the Government. Point h of Article 18(2) of Decree 320, unchanged in Consolidated Text 19/VBHN-BTC, still requires total investment capital to be disbursed within 10 years of licensing and still cites Article 20(2) of the 2020 Law on Investment; under Article 24(3) of Decree 320 that citation reads as Article 17(2) of Law 143. To get the point h CIT incentive, a project must therefore meet the capital threshold and minimum disbursement within 3 or 5 years in the table above to be a special incentive project, and also disburse its full registered capital within 10 years. A draft decree amending Decree 320, posted on 28 August 2026 and not yet issued, only updates the citation to Article 17 and keeps the 10-year limit. Do not confuse special incentives with the special investment procedure in Article 28 of the Law on Investment, which is a fast-track licensing route for projects in industrial parks, high-tech parks, functional zones of economic zones and similar areas, not an incentive level.
Expansion project incentives#
An expansion project develops an operating project by enlarging scale, raising capacity, upgrading technology, reducing pollution or improving the environment; a project independent of an operating one is a new project (Article 3(5) and (6) of the Law on Investment). The CIT rules for an expansion project cover two situations (Article 14(5) and (6) of Law 67; Article 20(5) and (6) of Decree 320):
- The original project is still within its incentive period: the additional income takes the original project's incentive for the remaining period, with no separate accounting.
- The original project's incentives have expired: the additional income gets an exemption and reduction (no preferential rate) for the same period as a new project in the same sector or area, starting from the year the registered capital is fully disbursed and income arises. The expansion must meet one of three tests: added fixed assets at historical cost of VND 40 billion or more (tax-preferential sector) or VND 20 billion or more (disadvantaged or extremely disadvantaged area); added fixed assets of at least 20% of the pre-expansion total; or added design capacity of at least 20%.
In the second case the additional income must be accounted for separately (or apportioned by the share of new fixed assets), and nothing is available until the registered expansion capital is fully disbursed. Expansion through merger or acquisition of an operating company or project does not qualify (Article 14(5)(c) of Law 67).
Two practical steps are often missed. First, the company notifies its tax office in writing of the registered capital for the expansion, together with its CIT finalisation return, no later than the year in which it carries out the expansion, and notifies again if that capital changes (Article 8 of Circular 20/2026/TT-BTC). Second, if the original investment registration already set out the capital, phases and timeline, later phases built on schedule count as component projects and share the remaining incentive period of the original project (Article 23(8)(d) of Decree 320). An expansion usually needs an amended IRC; see IRC amendment procedure in Vietnam.
IRC or self-assessment: how to claim investment incentives in Vietnam#
There is no separate certificate for investment incentives in Vietnam. Decree 96 sets out three paths to claim investment incentives in Vietnam (Article 24):
- Projects with an IRC, investment policy approval or investor approval. That document records the form, basis and conditions of the incentives (Article 24(1); Article 37(9)). The investor uses it to claim each incentive from the relevant authority: tax, customs or land (Article 24(2)). The incentive proposal is part of the project proposal filed for the IRC; see setting up a foreign-owned company in Vietnam, what an IRC is and investment policy approval.
- Science and technology enterprises, high-tech enterprises, supporting industry projects and encouraged technology transfers. The basis is the sector certificate (Article 24(3)); its issue date can move the start of the CIT incentive.
- Everything else. The investor self-assesses eligibility under Article 19 of Decree 96 and the relevant laws, then claims from the relevant authority (Article 24(4)).
The IRC does not override the tax law. For CIT, the company itself determines whether it meets the conditions for exemption, reduction and a preferential rate, the length of the holiday and the losses it can carry forward, and declares them in its returns and finalisation (Article 4(2) of Circular 20/2026/TT-BTC); if an inspection or audit concludes that the conditions were not met, the tax is recovered with late payment interest and penalties (Article 4(3)). Where the law allows self-assessment of an exemption or reduction, the tax office does not issue any decision or notice (Article 33(2)(a) of Decree 252/2026/ND-CP). Errors therefore tend to surface only at a tax audit.
Domestic investors do not need an IRC (Article 26(2)(a) of the Law on Investment) and can still claim incentives. For a project that needs no IRC, investment policy approval or sector licence, new-project status for CIT purposes is determined from the investment implementation report filed with the investment registration authority (Article 23(8)(a) of Decree 320). A domestic investor may also apply for an IRC voluntarily (Article 26(4)).
Import duty and land incentives are handled by customs and the land authorities under their own laws (for industrial park projects, see above). One land point matters on exit: an organisation that received a land levy or one-off land rent exemption or reduction must pay back the equivalent amount when it transfers the land use right or contributes it as capital, unless another law provides otherwise (Article 33(3)(b) and Article 41(5) of the Land Law 31/2024/QH15).
How investment incentives in Vietnam are lost and clawed back#
Investment incentives in Vietnam are performance-based and the investor must keep meeting the conditions throughout (Article 14(8) of the Law on Investment). The mechanisms:
- Period by period. In any period the conditions are not met, no incentive applies for that period (Article 23(3) of Decree 96). For CIT, that year is taxed at 20% and still counts towards the incentive period for sector or location incentives (Article 23(10) of Decree 320), so the lost year is not added back at the end.
- IRC conditions not met. The investor loses the incentive recorded on the IRC or approval, or the self-assessed incentive, if the project does not meet the corresponding conditions; if it meets other conditions, it takes the incentive for those instead (Article 23(2) of Decree 96).
- Repayment of past years. A VND 12,000 billion manufacturing project (point g) or special incentive project (point h) that still fails its conditions 3 years after licensing (5 years for point g), or in the 4th year after first revenue (the 6th year for point g), loses the incentive and must declare and pay the tax saved in earlier years; this is not treated as a false declaration. Delays for objective reasons are excluded if approved and reported to the Prime Minister (Article 23(10) of Decree 320).
- Back tax and penalties. A company that does not meet the CIT incentive conditions faces back tax and penalties (Article 18(5) of Law 67). The baseline condition is proper accounting, invoices and records with tax filed by declaration (Article 18(1)).
Restructuring and acquisitions. A project arising from a merger, consolidation, division, separation, change of owner or conversion does not get new-project CIT incentives; a change of owner includes a new project that takes over the old company's assets, premises and business lines, and the purchase of an operating project (Article 18(1) of Law 67; Article 23(8)(b) of Decree 320). The restructured company or the transferee of a project inherits existing incentives if it still meets the conditions (Article 12(5) of Law 67; Article 20(6) of Decree 96).
New business lines. A company set up from an investment project gets incentives only on income from the activity that met the conditions in its first enterprise registration or investment certificate; activities added later qualify only as an expansion project if they meet the tests (Article 23(8)(c) of Decree 320).
Reports are where conditions get checked. Disbursed capital, headcount and revenue in your investment reporting should match the figures behind the incentive.
Projects licensed before the new laws continue under their existing licences (Article 52(1) of the Law on Investment). For CIT, a new project from before 1 October 2025 that is still within its incentive period keeps the incentive for the remaining period under the rules in force when its IRC or investment policy approval was issued, and switches to Decree 320 for the remaining period if that gives more, counted from the 2025 tax year; a project that had no incentive before but qualifies now also gets it for the remaining period from the 2025 tax year (Article 20 of Law 67; Article 23(4) and Article 25(1) of Decree 320). Outside those transitional cases, income that used to qualify but no longer qualifies under Law 67 loses the incentive from 1 October 2025 (Article 25(3)). An industrial park factory licensed before 1 October 2025 and already enjoying a CIT incentive for its industrial park location therefore keeps it for the remaining period.
An expansion of that factory depends on when the expansion was licensed. If the expansion received or amended its IRC or investment policy approval, or filed its implementation report with the investment registration authority, before 1 October 2025, its incentive and start date follow the rules in force at that time (Article 25(2) of Decree 320). For an expansion licensed on or after 1 October 2025, Article 14(5) of Law 67 grants expansion incentives only to projects in a tax-preferential sector or location "specified in Article 12 of this Law"; industrial parks are not among them, and the Ministry of Finance reply above covers "new/expansion" projects together. There is no specific guidance yet for an original project still enjoying a grandfathered industrial park incentive that expands after that date (Article 14(5)(a) lets additional income share the original project's incentive). The reference to Article 12 points towards no incentive, so ask the competent tax office in writing before building it into the financial model.
Global minimum tax: how much of the incentive a large group keeps#
For large groups, the global minimum tax decides how much of the investment incentives in Vietnam is actually kept. Resolution 107/2023/QH15 introduced a top-up CIT under the global anti-base erosion rules from the 2024 financial year (Article 8(1)). It applies to constituent entities of multinational groups with consolidated revenue of EUR 750 million or more in at least 2 of the 4 preceding years (Article 2(1); Article 3(1) of Decree 236/2025/ND-CP).
Under the qualified domestic minimum top-up tax (QDMTT), if the effective tax rate of the group's Vietnamese entities is below 15%, Vietnam collects the difference: (15% minus the effective rate) multiplied by excess profit (Article 4(2) to (4) of Resolution 107). Excess profit is GloBE net income less a substance carve-out of 5% of tangible assets and 5% of payroll, with higher transitional percentages (for 2026, 9.4% of payroll and 7.4% of tangible assets, per the Appendix). The QDMTT return and payment are due within 12 months after the financial year end (Article 6(1) of Resolution 107); the group's GloBE information return (original or copy) is due 18 months after the year end for the first year the group is in scope and 15 months for later years (Article 16(5) of Decree 236). A draft decree amending Decree 236 to bring in the OECD "side-by-side" guidance of January 2026 had its appraisal file published by the Ministry of Justice in early August 2026 and had not been issued as of 14 October 2026.
A 10% rate plus a tax holiday can push the effective rate well under 15%, and the difference comes back as top-up tax. A simplified illustration that ignores the many adjustments: net income of 100, carve-out of 10 and an effective rate of 5% give top-up tax of about (15% - 5%) x 90 = 9. The QDMTT is zero if average Vietnamese revenue is below EUR 10 million and average income below EUR 1 million or a loss, where the entity elects this (Article 4(9)).
For groups above the global minimum tax threshold, cost-based support (training, R&D, infrastructure under Article 14(3) of the Law on Investment) or the Investment Support Fund for strategic investors and multinational groups (Article 16, details set by the Government) may be worth more than a low headline rate. For the wider compliance picture, see what an FDI company is in Vietnam.
When preparing a project proposal, LexData checks the investment incentives in Vietnam that the project can claim, comparing sector and location against both Decree 96 and the CIT law so the incentive basis written into the IRC application is accurate, through its company formation service, and reviews incentives again on expansions and capital increases through its IRC amendment service. Tax returns and finalisation remain with the company and its accountants and auditors.
