Currency and payments inside Vietnam: the dong-only rule and its exceptions, quotations and advertising, foreign-currency salaries, penalties, non-cash payment rules, exchange rates and export processing enterprises

The rule

The Ordinance on Foreign Exchange prohibits the use of foreign currency inside Vietnam except where the State Bank permits it, and Circular No. 32/2013/TT-NHNN, as amended, turns that principle into a detailed rule. Article 3 of the circular provides that, within Vietnam, transactions, payments, listings, advertisements, quotations, pricing and the writing of prices in contracts and similar agreements, including the conversion or adjustment of prices or contract values, may not be made in foreign currency, save for the cases listed in Article 4. The rule applies to residents, and every company established in Vietnam is a resident, however foreign its ownership (The foreign exchange control framework).

The breadth of the rule surprises many investors. It is not limited to payment: a quotation, a price list, a website advertisement or a tender price in US dollars is caught even if payment will be made in dong. It is not limited to the price itself: the circular also catches clauses that convert or adjust a dong price by reference to a foreign currency, which puts at risk the common practice of fixing a dong price that floats with the dollar exchange rate. Practice and court decisions on such indexation clauses have not been uniform, and the contractual drafting points are discussed in Commercial contracts in Vietnam; the cautious course is to fix a dong price and agree a periodic price review rather than an automatic link to the exchange rate.

The exceptions that matter in practice

Article 4 of the circular lists the permitted cases. For a foreign-invested business the important ones are these. Dealings with non-residents: a non-resident may price and pay for goods and services exported to it in foreign currency, and the resident supplier may quote, price and receive foreign currency; this is what allows a Vietnamese subsidiary to invoice its foreign parent, or a foreign customer, in dollars. Export processing enterprises: an export processing enterprise (EPE) may price and pay in foreign currency, by bank transfer, for goods bought from the domestic market for export production, and the domestic supplier may quote and receive foreign currency; EPEs may also deal with each other in foreign currency. Contractors under international bidding may bid in foreign currency for their offshore costs and receive transfers for those costs. Entrusted importers and exporters may use foreign currency with their principals.

Other exceptions cover duty-free shops and bonded warehouses; agents of foreign carriers, who may quote international freight in foreign currency but must be paid in dong; insurers for reinsured risks; air transport, hotels and tourism businesses, which may list prices in dong with the foreign-currency equivalent on their websites and specialist publications in a foreign language, but not on menus or price tables; and capital contributions in foreign currency by residents for foreign investment projects in Vietnam. Beyond the list, the Governor of the State Bank may approve other cases individually. A transaction that does not fit an exception must be in dong.

Foreign-currency salaries

Article 4 of the circular allows an organisation to agree in the labour contract, and to pay, salaries, bonuses and allowances in foreign currency to non-resident employees and to foreign employees who are residents. A foreign-invested company may therefore pay its expatriate general manager a dollar or euro salary into the employee's foreign-currency account; payment by bank transfer is the norm. Vietnamese employees must be paid in dong. Whatever the currency of payment, personal income tax, social insurance where applicable and the employer's accounting are computed in dong at the exchange rate the rules prescribe, so a fall in the dong increases the dong value of a foreign-currency salary for tax purposes (Personal income tax and expatriates; Wages, minimum wage and payroll).

Leases, intra-group dealings and other traps

Some arrangements that look natural to a foreign group are not permitted. An office or factory lease between a Vietnamese landlord and the Vietnamese subsidiary must be priced and paid in dong, although industrial park developers commonly quote rent with reference to dollar figures and then invoice in dong; the investor should ensure the contract price itself is a dong figure. Two Vietnamese subsidiaries of the same group must deal with each other in dong, even if their parent reports in dollars. A Vietnamese distributor may not be invoiced in dollars by the group's Vietnamese manufacturing company, although it may be invoiced in dollars by a foreign group company selling to it directly from abroad. And a foreign-invested company may not pay a Vietnamese contractor in dollars from its foreign-currency account, unless the contractor is an EPE or another exception applies.

Penalties and consequences

Decree No. 340/2025/ND-CP, in force from 9 February 2026 and replacing Decree No. 88/2019/ND-CP as amended by Decree No. 143/2021/ND-CP, sets the administrative fines for foreign exchange violations, including the use of foreign currency for listing, advertising, pricing or payment otherwise than as permitted. An organisation pays twice the fine prescribed for an individual. The commercial consequences can be more serious than the fine: a price clause in foreign currency between two residents may be treated as contrary to a prohibition of law, leaving the parties to argue over what price applies, and the tax authority may reject or recompute the transaction. Banks, for their part, will refuse to execute a foreign-currency payment between residents that does not fit an exception.

Cash and non-cash payments

Vietnam has moved decisively towards non-cash payment. Decree No. 52/2024/ND-CP governs non-cash payment services, and the tax rules now penalise cash payments by denying deductions. Under Law No. 48/2024/QH15 on Value Added Tax, in force from 1 July 2025, input VAT on a purchase of VND 5 million or more, including VAT, is deductible only if the company holds non-cash payment documents; cash deposited into the seller's account does not qualify, and several purchases from the same seller on the same day are aggregated. Under point c of clause 1 of Article 9 of Decree No. 320/2025/ND-CP, in force from 15 December 2025, an expense of VND 5 million or more per payment is deductible for corporate income tax only with non-cash payment documents. In practice a foreign-invested company should pay all suppliers by bank transfer and confine cash to petty expenses.

Large cash transactions are also visible. Under Law No. 14/2022/QH15 on Anti-Money Laundering and Decision No. 11/2023/QD-TTg, banks and other reporting entities report cash transactions of VND 400 million or more in a day to the State Bank. Foreign capital contributions and share-transfer payments must in any case pass through the investment capital account by bank transfer (The investment capital account).

Exchange rates and conversion

The State Bank publishes a daily central rate for the US dollar, and commercial banks may trade within a band of plus or minus 5% around it; in mid-August 2026, for example, the central rate was VND 25,586 per dollar, giving a ceiling of VND 26,865. Rates for other currencies are set by the banks. A company buys foreign currency from its authorised bank for permitted payments, presenting the supporting documents, and sells foreign currency receipts to the bank when it needs dong.

Taxes are declared and paid in dong, and statutory financial statements are presented in dong. The Law on Accounting permits a company that receives and spends mainly in a foreign currency to use that currency as its accounting currency if it meets the conditions, but its statutory statements must still be converted into dong. Foreign-currency revenue, expenses, assets and liabilities are converted at the rates prescribed by the accounting and tax rules, generally the actual rates of the commercial bank through which the company transacts, and realised and unrealised exchange differences affect taxable profit. A company with large dollar loans or receivables should model the exchange-rate effect on its tax and on the 30% of EBITDA interest cap.