Executive summary

On 18 December 2025, the Government of Vietnam promulgated Decree No. 324/2025/ND-CP (Decree), providing detailed guidance for implementing certain articles of Resolution No. 222. The Decree introduces distinctive preferential mechanisms and policies, as well as administrative support policies aimed at attracting global financial conglomerates, financial institutions and financial technology (fintech) companies to Vietnam.

In the context of financial centers' increasing shift toward Asia, Vietnam is among the markets with potential to establish competitive advantages. On 27 June 2025, the National Assembly passed the Resolution No. 222/2025/QH15 (Resolution) on the International Financial Center (IFC) in Vietnam, setting out provisions on the establishment, operation, management, supervision and special mechanisms and policies applicable to the IFC in Vietnam.

At present, the IFC is being established in Ho Chi Minh City and Da Nang City, Vietnam.

Investors in the IFC benefit from streamlined administrative procedures, greater flexibility in capital organization and ownership structures, and the ability to expand business into international financial services. In addition to these operational advantages, investors in the IFC are also entitled to preferential tax policies.

This Alert provides a brief summary of key preferential tax policies prescribed in the Decree.

Applicability

A member of the IFC is an entity recognized as a Member of the International Financial Center through registration, recognition as a Member, or being granted an establishment and operating license in accordance with the regulations, including:

• Commercial banks, branches of foreign bank, securities companies, insurance companies and reinsurance companies
• Investment and asset management funds
• Market infrastructure organizations
• Financial technology (fintech) and digital asset organizations
• Consulting and support service providers
• Non-financial organizations
• Other entities as prescribed by the Government

Organizations and enterprises apply for IFC membership when they meet the prescribed standards on financial capacity and creditability and have business activities consistent with the development orientation of the IFC, except for certain cases subject to separate regulations.

Members must locate their headquarters within the IFC and must maintain these headquarters throughout their entire operation.

Corporate Income Tax (CIT) policies

The income of enterprises from investment projects within the IFC area is entitled to the CIT incentive as outlined below:

• Income of enterprises from new investment projects in the encouraged sectors is subject to a CIT tax rate of 10% for 30 years, up to four years of tax exemption and 50% reduction for the subsequent nine years.
• Income of enterprises from new investment projects in the non-encouraged sectors is subject to a CIT rate of 15% for 15 years, up to two years of tax exemption and 50% reduction for the subsequent four years.
• For enterprises undertaking expansion investment projects within the area of the IFC, the principles, criteria and conditions for applying tax incentives comply with the current CIT regulations.

The list of sectors, products and services encouraged for development in the International Financial Center is set out in the Appendix to Government Decree No. 323/2025/ND-CP dated 18 December 2025 and includes the following main categories:

• Development of infrastructure of the IFC
• Green finance and finance associated with environmental, social and governance (ESG) factors
• Commodity markets, commodity derivatives and international trade finance
• Fintech and innovation
• Investment funds and asset management services
• Professional support services and other sectors

Personal Income Tax (PIT) policies

Income from salary and wages

Both Vietnamese and foreign individuals who meet the qualification and work experience requirements specified in the Decree, and who fall within the categories below, are eligible for tax exemption. These individuals must also be performing work and earning income within the IFC.

• Managers, experts, scientists and highly skilled professionals working at the IFC, including both Vietnamese and foreigners, are exempt from personal income tax on employment income (i.e., salaries and wages) earned from work performed in the IFC until the end of 2030.
• The tax exemption period is calculated continuously from the month in which tax-exempt income first arises. If income arises during a month, the exemption period covers the entire month.
• If an individual has both employment income eligible for tax exemption and other employment income, the exempted PIT amount is determined based on the proportion of income.

Income from capital investment

Individuals earning income from capital investments arising from ownership of contributed capital or shares in economic organizations that are members of the IFC are subject to the following rules:

• Income that individuals earn from the transfer of shares, contributed capital, or rights to contribute capital to an IFC Member is exempt from PIT until the end of 2030.
• An individual who sells an entire enterprise in the form of transfer of capital associated with immovable property, declares and pays PIT in accordance with regulations on real estate transfer activities.

Import-Export Tax policies

Goods and services that are exported and imported between the IFC and overseas are entitled to the preferential treatment provided under international treaties and domestic regulations.

An import-duty exemption applies to technical equipment, technology and software solutions that are not domestically produced and are imported to serve projects for building IT infrastructure, management and operation system, and large data centers of the IFC, in accordance with the list issued by the operation authority. The import-duty exemption applies to goods imported for the creation of fixed assets of investment projects within the IFC. This includes goods, raw materials, supplies and components that are not domestically produced and are imported to create fixed assets of investment projects within the IFC in accordance with the list issued by the Operation authority.

If the IFC is subject to treatment for investment incentive areas under the Law on Investment, goods imported to create fixed assets of investment projects within the IFC are exempted from import duty in accordance with the Law on Export and Import Duties.

Enterprises must notify List of Tax-exempt items per the regulations to enjoy the import-duty exemption.

Effectiveness

The Decree takes effect from 18 December 2025.

Implications

Investors should carefully evaluate the full range of incentives under the new IFC legal framework. These incentives provide improved tax efficiency, greater legal certainty, and enhanced flexibility in structuring their operations across the region.