Vietnam International Financial Center: Details on Tax Incentives and Investment Opportunities

At the Vietnam International Financial Center, a corporate income tax rate of 10% for 30 years applies to income from new investment projects belonging to priority development sectors; personal income tax exemption applies to managers, experts, and scientists.

On December 21, Vietnam officially announced the establishment of the International Financial Center with the "one center, two destinations" model located in Ho Chi Minh City and Da Nang City.

Here, investors, agencies, and organizations belonging to the International Financial Center; and other agencies, organizations, and individuals related to the operation of the International Financial Center will be subject to tax policies under Decree No. 324/2025/ND-CP.

Application of 10% corporate income tax rate for 30 years for income from new investment projects belonging to priority development sectors

The Decree details corporate income tax and personal income tax policies applicable to the International Financial Center.

Specifically, regarding corporate income tax, the Decree prescribes the application of a corporate income tax rate of 10% for a period of 30 years, corporate income tax exemption for a maximum of not more than 04 years, and a 50% reduction of tax payable for a maximum of not more than the next 09 years for enterprise income from the implementation of new investment projects arising within the International Financial Center area belonging to priority development sectors at the International Financial Center.

Application of a corporate income tax rate of 15% for a period of 15 years, corporate income tax exemption for a maximum of not more than 02 years, and a 50% reduction of tax payable for a maximum of not more than the next 04 years for enterprise income from the implementation of new investment projects arising within the International Financial Center area not belonging to priority development sectors at the International Financial Center.

The duration of application of preferential tax rates for income from the implementation of new investment projects of enterprises mentioned above is calculated from the first year the enterprise's new investment project generates revenue. The tax exemption and reduction period is calculated from the first year of having taxable income from the investment project; in case there is no taxable income in the first 03 years, counting from the first year of having revenue from the implementation of the new investment project arising within the International Financial Center area, the tax exemption and reduction period is calculated from the 04th year.

Enterprises shall account separately for income from the implementation of investment projects arising within the International Financial Center area eligible for tax incentives mentioned above and income from production and business activities not eligible for tax incentives; in case separate accounting is not possible, the portion of income from activities eligible for tax incentives is determined by (=) total taxable income multiplied (x) by the percentage (%) of revenue or deductible expenses of the production and business activities eligible for tax incentives over the total revenue or total deductible expenses of the enterprise in the tax period.

In case there is an item of revenue or deductible expense that cannot be accounted for separately, that revenue or deductible expense item shall be determined according to the ratio between revenue or deductible expenses of production and business activities enjoying tax incentives and the total revenue or deductible expenses of the enterprise.

In the same period, if the enterprise has income from the implementation of a new investment project arising within the International Financial Center area as prescribed above that is eligible for incentives different from the regulations in this Decree, the enterprise may choose to enjoy the most beneficial tax incentive according to the regulations of the law on corporate income tax.

In case a new investment project of an enterprise has a duration of less than 12 months in the first year of generating revenue or income eligible for tax incentives, the enterprise may choose to enjoy tax incentives (tax rate, tax exemption, tax reduction duration) for the investment project right from the tax period generating that revenue or income or register with the tax authority for the time to start enjoying tax incentives from the following tax period.

In case the enterprise registers the time to apply tax incentives for the new investment project in the following tax period, it must determine the tax payable from this investment project in the first year of generating revenue and income to pay into the state budget according to regulations.

In case the enterprise converts the corporate income tax period (including conversion of the tax period from the calendar year to the fiscal year or vice versa), the corporate income tax period of the conversion year shall not exceed 12 months.

Enterprises that are in the period of enjoying corporate income tax incentives and perform a conversion of the tax period may choose: Incentives in the year of tax period conversion or pay tax at the rate not enjoying incentives in the year of tax period conversion and enjoy tax incentives in the following year.

In case an enterprise implements an expansion investment project belonging to priority development sectors at the International Financial Center and the International Financial Center area, the principles, criteria, and conditions for applying tax incentives shall be implemented according to the provisions of the current law on corporate income tax.

Decree No. 324/2025/ND-CP comprises 9 chapters, 76 articles detailing and guiding the implementation of a number of articles of Resolution No. 222/2025/QH15 dated June 27, 2025, regarding members of the International Financial Center; tax policies, tax administration, and accounting; financial regimes in the banking sector; licensing for establishment and operation of securities business organizations; insurance and reinsurance policies; policies on capital market development and controlled testing (sandbox) for financial services applying technology and innovation; policies for strategic investors and policies for development of technical infrastructure and social infrastructure; inspection, examination, and supervision within the International Financial Center…

Applicable subjects are members of the International Financial Center in Vietnam (hereinafter referred to as Members); investors; agencies and organizations belonging to the International Financial Center; and other agencies, organizations, and individuals related to the operation of the International Financial Center in Vietnam as prescribed in Resolution No. 222/2025/QH15.

Personal income tax exemption for managers, experts, scientists, and highly qualified personnel until the end of 2030

Regarding personal income tax, the Decree stipulates that managers, experts, scientists, and highly qualified personnel working at the International Financial Center, including Vietnamese and foreigners, are exempt from personal income tax on income from salaries and wages derived from performing work at the International Financial Center until the end of 2030.

The tax exemption period is calculated continuously from the month income eligible for tax exemption arises. In case income arises within a month, the tax exemption period is calculated as a full month.

In case an individual has both income from salaries and wages eligible for tax exemption as prescribed in this point and income from other salaries and wages, the amount of personal income tax exempted as prescribed in this point is determined as follows:

Individuals having income from the transfer of shares, capital contributions, or capital contribution rights into Members are exempt from personal income tax on this income until the end of 2030.

Income from the transfer of shares, capital contributions, or capital contribution rights prescribed in this point is income derived from the transfer of a part or all of shares, capital contributions, or capital contribution rights into Members (including cases of selling enterprises), excluding income from the transfer of stocks or rights to buy stocks of public companies or listed organizations registered for trading according to the provisions of the law on securities.

In case of selling the entire enterprise owned by an individual in the form of capital transfer attached to real estate, declare and pay personal income tax according to real estate transfer activities.

The Operating Body determines specific criteria and conditions for each professional field suitable to the requirements of the International Financial Center. The Chairperson of the Operating Body has the authority to determine and select managers, experts, scientists, and highly qualified personnel based on the proposal of agencies and units belonging to the International Financial Center and Members.

In case enterprises or individuals generate other corporate income tax or other personal income tax subject to tax outside the regulations of this Decree, they shall comply with current regulations of the law on corporate income tax, personal income tax, and tax administration.

Enterprises and individuals at the International Financial Center performing registration, declaration, tax payment, and finalization of taxes are entitled to priority regimes regarding administrative procedures in tax management according to the regulations of the law on tax administration. The determination of the starting time for enjoying incentives, tax exemption, and reduction periods is implemented according to the law on corporate income tax and the law on personal income tax.

The list of priority development sectors at the International Financial Center applying corporate income tax incentives is prescribed in the Government's Decree on the establishment of the International Financial Center in Vietnam.

Managers, experts, scientists, and highly qualified personnel must meet at least the following criteria and conditions: Have a university degree or higher or a prestigious professional certificate recognized by international professional organizations; at least 05 years of experience in working, researching, or teaching in a professional field suitable to the requirements of the International Financial Center; or have held or are holding managerial titles from head of department level or higher at International Financial Centers worldwide or at reputable financial institutions, investment funds, or multinational corporations.

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