Question: Is foreign salary transferred to a Vietnamese bank account subject to tax?

Answer: The Tax Department of Ca Mau Province responds to this matter as follows:

Pursuant to Articles 4, 5, and 6 of Government Decree No. 253/2026/ND-CP dated June 30, 2026, detailing a number of articles and measures for the implementation and enforcement of the Law on Personal Income Tax:

"Article 4. Tax Residents: A tax resident is an individual who satisfies one of the conditions specified in Clause 2, Article 2 of the Law on Personal Income Tax, detailed as follows:

1. Being present in Vietnam for 183 days or more in a calendar year or in 12 consecutive months from the date of first arrival in Vietnam. For incoming and outgoing individuals, the arrival date and departure date are each counted as one day; in the event that arrival and departure occur on the same day, it shall be counted as one day of residence. Arrival and departure dates are determined based on the certification of the immigration authority stamped on the passport, laissez-passer, or relevant documents verifying the individual's entry and exit purposes upon arriving in and departing from Vietnam. An individual present in Vietnam under this Clause means their physical presence on the territory of Vietnam.

2. Having a regular residence in Vietnam in either of the following cases: a) Having a registered permanent residence, specifically: ... For foreign nationals: the permanent residence stated in the Permanent Residence Card, or the temporary residence declared when applying for the Temporary Residence Card issued by the competent authority under the Ministry of Public Security; b) Renting a residential house in Vietnam in accordance with the law on housing, with a lease term under lease agreements of 183 days or more in the tax year, specifically: An individual who does not have or has not established a regular residence as guided in Point a of this Clause, but has a total duration of renting residential houses under lease agreements of 183 days or more in the tax year, is also determined to be a tax resident, including cases of leasing residences in multiple locations. Rented houses for residential purposes encompass stays in hotels, guesthouses, motels, dormitories/inns, workplaces, or head offices, regardless of whether leased directly by the individual or by the employer on the employee's behalf.

3. Where an individual maintains a regular residence in Vietnam under Clause 2 of this Article but is physically present in Vietnam for fewer than 183 days in the tax year, and fails to prove their tax residency in any other jurisdiction, such individual shall be deemed a tax resident in Vietnam. Proof of residency in another country shall be established based on a Certificate of Residence. Where an individual originates from a country or territory that has concluded a Double Taxation Avoidance Agreement and the Prevention of Fiscal Evasion with Vietnam which does not issue Certificates of Residence, the individual shall provide a copy of their Passport to substantiate the period of residence.

Article 5. Non-residents: A non-resident under Clause 3, Article 2 of the Law on Personal Income Tax is an individual who does not satisfy the criteria set forth in Article 4 of this Decree.

Article 6. Taxable Income: ... 2. The scope of determining taxable income for residents and non-residents is prescribed as follows: a) For tax residents, taxable income is income arising within and outside the territory of Vietnam, regardless of where the income is paid and received; b) For non-residents, taxable income is income arising within the territory of Vietnam, regardless of where the income is paid and received."

Based on the aforementioned regulations and the information provided by Ms. Bich Tram, the determination of Personal Income Tax (PIT) liabilities in Vietnam regarding the salary received is specified as follows:

• In case the foreign national is a tax resident in Vietnam: Taxable income encompasses income arising both within and outside the territory of Vietnam, regardless of where the payment is made or received. Consequently, the salary paid by the company in Japan to the foreign national is subject to PIT in Vietnam. The taxpayer is entitled to credit the income tax paid in Japan against the PIT payable in Vietnam. The maximum credit allowed in Vietnam shall not exceed the PIT amount calculated under Vietnam's progressive tax bracket allocated to the income arising in Japan. Where the tax liability payable in Vietnam is higher than the tax already paid in Japan, the taxpayer must remit the shortfall to the State Budget of Vietnam.

• In case the foreign national is a non-resident in Vietnam: This income does not constitute taxable PIT income in Vietnam. The remittance of the salary into an account opened at a bank in Vietnam does not trigger PIT obligations with respect to this income.

Source: The Electronic Information Portal of the Government.