Profit repatriation in Vietnam works on an annual cycle. A foreign investor may remit its share of profit once the financial year has closed and the Vietnamese company has filed its audited financial statements and its annual corporate income tax (CIT) finalisation return, has paid all tax, late-payment interest and penalties that have fallen due, and has no outstanding tax debt on the day the money leaves (Article 27(6)(a) of Decree 252/2026/ND-CP). Profit for a year cannot be remitted if that year's financial statements still show accumulated losses (Article 27(6)(c)). The transfer goes through the company's investment capital account (Article 12(1) of Circular 38/2026/TT-NHNN), and a notice should reach the company's tax office at least 7 working days beforehand (Article 5 of Circular 186/2010/TT-BTC).
Profit repatriation in Vietnam does not trigger a separate "repatriation tax". A foreign parent company receives dividends from a Vietnamese company free of CIT; a foreign individual shareholder suffers 5% personal income tax, withheld by the company before payment. This guide reflects the texts in force on 13 October 2026.
The legal basis for profit repatriation in Vietnam in 2026#
Article 11 of the Law on Investment 143/2025/QH15 guarantees that a foreign investor, after fulfilling its financial obligations to the State, may transfer abroad its invested capital, liquidation proceeds, income from investment and business activities, and other lawfully owned assets. The working rules sit in four places:
| Topic | Instrument | Provision |
|---|---|---|
| Annual remittance, remittance on exit, accumulated losses | Decree 252/2026/ND-CP (in force 1 July 2026) | Article 27(6)(a) to (c) |
| Which profit qualifies, how the amount is computed, notice to the tax office | Circular 186/2010/TT-BTC | Articles 2, 3, 5 and the notice form |
| How the money moves: investment capital account, bank checks | Circular 38/2026/TT-NHNN (in force 18 August 2026) | Articles 8, 9, 12, 14 |
| Whether the company may distribute at all | Law on Enterprises 59/2020/QH14 | Article 69, Article 77(6), Article 135 |
Three 2026 points to check when reading older guides:
- Decree 252 replaced Decree 126/2020/ND-CP from 1 July 2026 (Article 74(1) and (3)(a)). Compared with Article 4(1) of Circular 186, Article 27(6)(a) adds that tax, other State charges, late-payment interest and administrative fines due must be paid, and that the company must have no tax debt at the moment of remittance.
- Circular 38/2026 replaced Circular 06/2019/TT-NHNN from 18 August 2026 (Article 18(1) and (2)). The account formerly called the direct investment capital account (DICA) is now the "foreign investment capital account in Vietnam", shortened to investment capital account (Article 3(3) and Article 18(5)). A company established by a foreign investor always needs one (Article 6(1)(a)); a company that takes in foreign capital through a contribution or a share or capital purchase needs one when foreign investors hold more than 50% of its charter capital (Article 6(1)(b)).
- Circular 186/2010 does not appear to have been repealed. It is not on the repeal lists in Article 99(3) and (4) of Circular 89/2026/TT-BTC (in force 1 July 2026), nor, according to the Ministry of Finance newspaper Thoi bao Tai chinh Viet Nam, among the instruments repealed by Circular 110/2026/TT-BTC from 12 September 2026. It was written under the 2005 investment law, but until it is formally withdrawn the prudent course is to keep filing its notice.
Conditions for profit repatriation in Vietnam: a checklist#
Combining Decree 252, Circular 186 and the Law on Enterprises, check these conditions for profit repatriation in Vietnam in order before instructing the bank:
- The financial year has ended. Annual profit is remitted "at the end of the financial year" (Article 27(6)(a) Decree 252; Article 4(1) Circular 186).
- Audited financial statements for that year have been filed with the tax office that manages the company. Article 27 makes no exception by company size.
- The CIT finalisation return has been filed. The deadline is the last day of the third month after the end of the tax finalisation period (Article 10(5)(a) Decree 252), so 31 March for a calendar year.
- Tax, other State charges, late-payment interest and fines that have fallen due are paid, and there is no tax debt on the remittance date. The provision is not limited to CIT, so small arrears on other taxes (foreign contractor tax, employees' withheld personal income tax) should be rechecked just before the transfer.
- The financial statements for the profit year show no accumulated losses after loss carry-forward under CIT law (Article 27(6)(c) Decree 252; Article 3(3) Circular 186).
- A valid distribution decision exists. The company may distribute only after meeting its tax and other financial obligations, and must still be able to pay its debts and obligations as they fall due after the distribution (Article 69 and Article 77(6) Law on Enterprises). A joint stock company must also have made its fund allocations and covered prior losses (Article 135(2)(b)) and must pay dividends within 6 months after the annual general meeting ends (Article 135(4)).
- The profit remittance notice has been filed with the company's tax office at least 7 working days before the transfer (Article 5 Circular 186).
- The money moves through the investment capital account, with each payment order stating the amount and purpose (Article 12(1) and Article 14(2) Circular 38).
There is no approval step. Circular 186 asks for a notice and does not provide for a clearance letter from the tax office. Guidance that still cites Circular 124/2004/TT-BTC is out of date; that circular was replaced by Circular 186 (Article 6).
How accumulated losses block profit repatriation in Vietnam#
Article 27(6)(c) of Decree 252 carries over the rule in Article 3(3) of Circular 186: profit for a year cannot be remitted if the investee's financial statements for that year still show accumulated losses after losses have been carried forward under CIT law. Tax losses may be carried forward for up to 5 consecutive years from the year after the loss year (Article 16(1) of Law 67/2025/QH15).
Illustration (hypothetical figures, VND billion): Company B is wholly owned by a Korean group and has accumulated losses of 3.0 at 31 December 2025.
- 2026 profit before tax of 2.0. After absorbing the losses the company still has accumulated losses of 1.0 at the end of 2026, pays no CIT and has nothing to distribute or remit for 2026.
- 2026 profit before tax of 5.0. The losses absorb 3.0, taxable income is 2.0, and at the standard 20% rate (Article 10(1) Law 67) CIT is 0.4. Retained earnings at the end of 2026 are 5.0 − 3.0 − 0.4 = 1.6, assuming no non-deductible items. No accumulated losses remain, so profit distributed out of that 1.6 can be remitted once the audited statements and the finalisation return are filed.
Accounting losses and tax losses carried forward can differ (non-deductible costs, losses older than 5 years). The rule refers to accumulated losses in the financial statements "after carry-forward" under tax law without saying what happens when the two figures diverge, so settle the approach with the auditor. The example uses 20% because the 15% and 17% small-company rates (Article 10(2) and (3) Law 67) do not apply to a subsidiary or associated company whose related enterprise does not itself meet those revenue tests (Article 18(4) Law 67), the usual position of a foreign group's subsidiary; see how to calculate corporate income tax in Vietnam.
Annual, mid-year or several years at once?#
No interim remittance of the current year's profit. This is a reading of the wording of Article 27(6)(a): annual profit is remitted "at the end of the financial year", after the audited statements and finalisation return for that year are filed. The texts provide no route for remitting quarterly or half-year profit, even where provisional CIT has been paid. Groups that pay interim dividends elsewhere should build this timing of profit repatriation in Vietnam into the subsidiary's cash plan.
Any time after the conditions are met. Nothing sets a deadline or requires the investor to repatriate profit every year. 2026 profit can be remitted in April 2027 or in October 2027, provided the "no tax debt" test is met on the day. The investor may also leave the profit in Vietnam and reinvest.
Prior years can be added. Article 3(1) of Circular 186 defines the amount remittable each year as the profit distributed for the financial year (per the audited statements and finalisation return), plus profit from earlier years not yet remitted, minus amounts used or committed for reinvestment in Vietnam, minus amounts used to cover the investor's business or personal spending in Vietnam. When remitting several years together, attach the year-by-year figures with the matching audited statements and returns. Profit may be remitted in cash under foreign exchange rules or in kind, valued under import and export rules (Article 2(2) Circular 186).
Remitting profit on exit: taxes not yet due must be settled too#
When the direct investment ends, Article 27(6)(b) of Decree 252 keeps the same filings and the duty to perform all obligations under the Law on Tax Administration, and states that this covers tax obligations that are not yet due (Article 4(2) of Circular 186 did not say so). A company being dissolved, or ending its project, therefore closes out every tax item before the final round of profit repatriation in Vietnam.
The amount remittable on exit is total profit earned over the life of the investment, less amounts reinvested, amounts already remitted and amounts spent in Vietnam (Article 3(2) Circular 186). The tax finalisation on termination or dissolution is due by the 45th day after the decision (Article 10(5)(b) Decree 252). Capital returned on dissolution or a capital reduction is a separate flow governed by Article 11 of Circular 38, not profit. For the full sequence, see terminating an investment project in Vietnam.
Profit repatriation in Vietnam step by step, with a dated timeline#
1. Close the year. Complete the audit, file the audited statements and the CIT finalisation return, pay any balance. Clear any other late returns or unpaid late-payment interest first.
2. Approve the distribution. The owner (single-member LLC), the members' council or the general meeting fixes the amount for each member or shareholder. This document underpins both the tax notice and the bank file.
3. File the profit remittance notice. The investor files it directly or authorises the company to file it, using the form attached to Circular 186, with the tax office that directly manages the company, at least 7 working days before the transfer (Article 5). The form covers the investor and the company, its tax code, a table of profit distributed, profit already used (reinvestment, other purposes) and profit to be remitted this time, the currency or goods, and the bank account. The company's legal representative signs; if the company files under authority, the investor does not need to sign. The 2010 form still has a box for the "investment licence number"; it is sensible to enter the investment registration certificate number or enterprise code.
4. Instruct the bank that holds the investment capital account. Profit usually sits in the operating account, so the company first moves it into the investment capital account; Circular 38 permits this credit when the purpose is to remit profit abroad (Article 8(1)(e) for foreign currency, Article 9(1)(dd) for dong). The circular does not list documents. Each bank issues internal rules, requires the amount and purpose on every payment order (Article 14(2)) and checks documents against the actual transaction (Article 14(3)); the investor is responsible for the authenticity of what it provides (Article 15(2)). The documents that map onto the legal conditions are the audited statements, the CIT finalisation return, tax payment receipts, the distribution decision and the filed notice; confirm the bank's own list in advance.
Illustrative timeline. Company C is a single-member LLC wholly owned by a Singapore parent, with a calendar financial year and no accumulated losses.
| Date | Step | Basis |
|---|---|---|
| Thursday 31 December 2026 | Financial year 2026 ends | Article 27(6)(a) Decree 252 |
| Monday 22 March 2027 | File audited statements and the 2026 CIT finalisation return, pay the balance (deadline 31 March 2027) | Article 10(5)(a) Decree 252 |
| Friday 26 March 2027 | Owner decides to distribute VND 8 billion of 2026 profit | Article 77(6) Law on Enterprises |
| Monday 29 March 2027 | Company, under the parent's authority, files the remittance notice | Article 5 Circular 186 |
| Thursday 8 April 2027 | Earliest prudent transfer date: 7 full working days from 30 March to 7 April, with no public holiday in the window (Hung Kings' Day falls on 16 April in 2027); recheck that no tax debt exists. The company moves VND 8 billion from its operating account into its dong investment capital account, buys foreign currency and pays the parent | Article 5 Circular 186; Article 27(6)(a) Decree 252; Article 9(1)(dd) and (2)(c) Circular 38 |
The parent is a company, so nothing is withheld on the VND 8 billion (see the tax section). If Company C instead remits in September 2027, it files a notice tied to the new date and rechecks its tax position then.
Which account is used for profit repatriation in Vietnam?#
For profit repatriation in Vietnam, the money must leave through the investment capital account (Article 12(1) Circular 38), the account still widely called the DICA. The Law on Enterprises also requires dividends received and profit remitted by foreign investors to be paid through an account under the foreign exchange rules (Article 35(5)).
- Foreign currency account: pays profit in foreign currency abroad or into the investor's payment account at a licensed bank (Article 8(2)(d)); a currency conversion is allowed where the remittance currency differs from the account currency (Article 8(2)(h)).
- Dong account: buys foreign currency to remit profit abroad (Article 9(2)(c)) or remits profit in dong (Article 9(2)(g)). Banks sell foreign currency based on their own foreign currency balance (Article 14(5)).
- Profit kept in Vietnam moves from the investment capital account to the investor's payment account for other projects or investment activities in Vietnam (Article 12(2)).
The exception is an account that had to be closed under Article 7(5)(a) (no foreign investor left, dissolution, bankruptcy, termination and similar cases): later lawful receipts may then go to the investor's payment account or abroad (Article 7(5)(c)). For who must open the account, how many accounts and changing banks, see the direct investment capital account in Vietnam.
Is there dividend withholding tax on profit repatriation in Vietnam?#
Vietnam levies no dividend withholding tax on a corporate investor. It taxes the profit once, at the level of the Vietnamese company; distribution adds tax only where the recipient is an individual.
| Recipient | Tax on the distributed profit | Basis |
|---|---|---|
| Foreign company (for example the parent) | No CIT: income distributed from capital contributions or shareholdings in a domestic enterprise, after that enterprise has paid CIT, is exempt, even where the enterprise enjoys CIT incentives | Article 4(7) and Article 2(1)(b) Law 67/2025 |
| Individual who is the owner of a single-member limited liability company | Exempt from personal income tax on income received after the company has paid CIT | Article 4(21) Law 109/2025; Article 39 Decree 253/2026 |
| Non-resident individual | 5% personal income tax on the gross amount received | Article 3(3)(b) and Article 22 Law 109/2025 |
| Resident individual (including a foreigner present 183 days or more, or with a regular residence) | 5% personal income tax on investment income | Article 2(2) and Article 12(1) Law 109/2025; Article 52(1) Decree 253/2026 |
For individuals, the paying company withholds and pays the tax before paying out (Article 67(1) of Decree 253/2026/ND-CP); dividends are not among the income types excluded from withholding in Article 67(4). Example: Company D, a joint stock company with an investment capital account, pays a VND 1 billion dividend to a non-resident Japanese individual; it withholds VND 50 million, pays it to the State budget and remits VND 950 million through the investment capital account. A double tax treaty may set a different rate; check the treaty and its claim procedure before payment.
Two flows are often confused with profit:
- Interest, royalties and service fees paid to the parent are income of a foreign contractor and attract foreign contractor tax (interest, for example, bears CIT at 5% of taxable revenue under Article 12(3)(e) of Decree 320/2025/ND-CP), not dividend treatment; see foreign contractor tax in Vietnam and foreign loan registration in Vietnam.
- Capital returned on a capital reduction or project termination is not profit and moves under Article 11 of Circular 38; a gain on selling the stake is taxed as a capital transfer, see CIT on capital transfers in Vietnam.
Branches, BCC investors and stakes of 50% or less#
A branch of a foreign company is not an enterprise with foreign capital contributions; its right to repatriate profit comes from Article 19(5) of the Commercial Law. Article 27(6)(a) of Decree 252 refers to "the enterprise in which the foreign investor invests", so confirm with the branch's tax office how the conditions and notice apply. See branch office in Vietnam.
A foreign investor in a business cooperation contract (BCC) opens its own investment capital account (Article 6(2) Circular 38), a separate one for each contract where it has several (Article 7(2)), and its profit share leaves through that account; income from a BCC is CIT-taxable income (Article 3(2)(l) Law 67). Because Article 27 of Decree 252 is framed around "the enterprise" in which the investor invests, agree in advance with the tax office who files the statements, finalisation and notice for BCC profit. See business cooperation contracts in Vietnam.
A company in which foreign investors hold 50% or less through contributions or share or capital purchases is outside the account requirement (Article 6(1)(b) Circular 38). Where such a company's foreign ownership falls to 50% or less after a transfer or charter capital change, or any account holder becomes a public company listed or registered for trading, the account must be closed (unless it is still used for foreign loans or other lawful payment obligations); the foreign investor then transacts, including receiving dividends, through an indirect investment account (Article 7(5)(b)). Article 27(6) of Decree 252 is written for profit "from direct investment activities" and does not define that phrase, so the text does not say whether the tax and accumulated-loss conditions above apply to an investor holding 50% or less. On our reading, a foreign shareholder that takes part in managing the company should play safe and meet those conditions before remitting; a purely portfolio investor should confirm in advance with its account bank and the tax office, including how any notice is to be filed.
Repatriation runs alongside the other annual filings of a foreign-invested company, covered in investment reporting obligations in Vietnam and what an FDI company is. LexData reviews the conditions, the distribution decision, the tax office notice and the capital account flow through its foreign investment advisory service; audits and tax filings are handled by the company with its accountants and auditors.
