Investment incentives: preferential corporate income tax, tax holidays, import duty and land relief, special incentives, the Investment Support Fund and the global minimum tax

The architecture

Vietnam's incentives are set by three bodies of law working together. The Law on Investment (Articles 15 to 18) decides who qualifies: projects in incentivised sectors, projects in incentivised locations, large-capital and labour-intensive projects, and high-impact projects eligible for special incentives, with the detailed lists in Decree No. 96/2026/ND-CP. The tax laws decide what the incentive is worth: Law No. 67/2025/QH15 on Corporate Income Tax and Decree No. 320/2025/ND-CP for rates and holidays, Law No. 107/2016/QH13 on Export and Import Duties for duty exemptions, and the Land Law and its decrees for land rent and land use levy relief. Resolution No. 107/2023/QH15 and Decree No. 236/2025/ND-CP then impose the 15% global minimum tax on large groups, which can take back what the CIT incentive gave, and Decree No. 182/2024/ND-CP creates the Investment Support Fund to compensate the largest high-tech investors in cash. An incentive analysis that reads only one of these layers will be wrong.

The forms incentives take

The Law on Investment lists four forms: corporate income tax incentives (a lower rate for a period or for the life of the project, exemption and reduction); exemption from import duty on goods imported to create fixed assets and on raw materials, supplies and components for production; exemption from or reduction of land use levy, land rent and land use tax; and accelerated depreciation or an increased deductible expense allowance. Incentives apply to new investment projects and to qualifying expansion projects, are time-bound and performance-based, and where a project qualifies on more than one ground the most favourable level applies for the longest period. Mineral extraction, the production of goods subject to special consumption tax (other than cars, aircraft and yachts) and commercial housing are excluded from certain incentives.

Preferential corporate income tax

The standard CIT rate is 20%, with 15% and 17% for smaller enterprises by revenue (Chapter 3). Under Law No. 67/2025/QH15, qualifying new projects in high technology, software, semiconductors, artificial intelligence data centres, renewable and clean energy, key infrastructure and priority supporting industries, and projects located in especially disadvantaged areas, economic zones and high-tech parks, pay 10% for 15 years. Income from qualifying socialised education, health, culture, sport and environment activities, and from certain agriculture, forestry and fisheries activities in disadvantaged areas, is taxed at 10% for the life of the activity. A 15% rate applies to certain agricultural activities outside incentivised areas, and 17% for 10 years to qualifying projects such as some manufacturing projects and projects in disadvantaged areas. The rate period runs from the first year of revenue; the Prime Minister may extend the 10% period by up to 15 further years for large or strategic projects.

High-tech enterprises from 1 July 2026. Law No. 133/2025/QH15 on High Technology, passed on 10 December 2025 and in force from 1 July 2026, replaced Law No. 21/2008/QH12 and, by its Article 25(7), amended the CIT Law. Group 1 high-tech enterprises, strategic technology enterprises and high-tech and strategic technology research and development centres now pay 10% for 25 years, with four years' exemption and nine years at 50%. Group 2 high-tech enterprises keep 10% for 15 years with the same holiday, and enterprises manufacturing high-tech products pay 17% for 10 years with two years' exemption and four years at 50%. The separate high-tech agricultural enterprise certificate was not continued: certificates issued under the 2008 law keep their incentives until they expire (Incentives and high-tech agriculture). Decree No. 260/2026/ND-CP of 30 June 2026 sets the criteria for each category; the Ministry of Science and Technology certifies Group 1 enterprises, strategic technology enterprises and Group 2 enterprises with capital of VND 6,000 billion or more, and provincial Departments of Science and Technology the others. A Ministry of Finance decree amending Decree No. 320/2025/ND-CP to implement these rates was still in draft in September 2026.

How the holiday runs

The holiday starts in the first year in which the project has taxable income, or in the fourth year from the first year of revenue if there is no taxable income in the first three years, whichever is earlier. The exemption and reduction apply to income from the incentivised project, so a company that also earns non-incentivised income accounts for the two separately and allocates common costs. Qualifying expansion projects, those that add capacity, upgrade technology or increase fixed assets above set thresholds, can receive the incentive of the original project for its remaining period or a fresh holiday on the expansion income. Projects already enjoying incentives under earlier law are protected by the grandfathering rule in Law No. 67/2025/QH15 for the remainder of their period. The Ministry of Finance has confirmed that new projects in industrial parks from 1 October 2025 obtain no CIT incentive on location alone unless the park lies in a disadvantaged area or the project qualifies by sector; that single change removed the incentive most ordinary manufacturing tenants had relied on.

Sectors and locations that qualify

The Law on Investment 2025 prioritises science, innovation, digital technology and semiconductors; the green, circular and digital economy; value chains and supporting industries; renewable and clean energy; agriculture, forestry and the environment; infrastructure; education, health, sport and culture; and key chemical, mechanical and pharmaceutical industries. Incentivised locations are areas with difficult or especially difficult socio-economic conditions (listed by district in the decree), industrial parks and clusters, export processing zones, economic zones, high-tech parks, concentrated digital technology zones, free trade zones and the international financial centre. The lists in Decree No. 96/2026/ND-CP govern eligibility under the Law on Investment, but the CIT law has its own lists and definitions, which is why a project can be incentivised for land rent purposes and not for CIT.

Special incentives for very large projects

Article 17 of the law provides special incentives and support for high-impact projects, and Decree No. 96/2026/ND-CP sets the thresholds: innovation centres, research and development centres and major digital infrastructure with capital of at least VND 3,000 billion of which VND 1,000 billion is disbursed within three years; semiconductor chip, key digital technology product and artificial intelligence data centre projects with VND 6,000 billion disbursed within five years; and other projects in specially incentivised sectors with VND 30,000 billion of which VND 10,000 billion is disbursed within three years. The incentive levels are those the CIT and land laws allow at their maximum (a preferential rate for up to one and a half times the ordinary period, exemption and reduction for up to 6 and 13 years, and land rent exemption for up to 22 years with a 75% reduction thereafter, on the pattern of Decision No. 29/2021/QD-TTg), and the Prime Minister may decide further incentives for especially important projects by individual decision. The former CIT incentive based on capital size alone (VND 6,000 billion) was not carried into the new CIT Law, so size without sector no longer earns a rate.

The global minimum tax and the Investment Support Fund

Since the 2024 financial year Vietnam applies the OECD Pillar Two rules through Resolution No. 107/2023/QH15 and Decree No. 236/2025/ND-CP: a qualified domestic minimum top-up tax on Vietnamese constituent entities of groups with consolidated revenue of at least EUR 750 million in two of the preceding four years, and an income inclusion rule for Vietnamese-parented groups. A Vietnamese subsidiary of such a group that pays an effective 10% under an incentive is topped up to 15% in Vietnam, so for groups above the threshold the value of a CIT holiday is reduced to the difference between the holiday and 15%, and the holiday years themselves are largely neutralised. The Investment Support Fund, established by Decree No. 182/2024/ND-CP, is the policy response: it pays tax-free cash support towards training, research and development, fixed assets, high-tech production and social infrastructure to qualifying high-tech enterprises, high-tech product manufacturers and research centres, broadly those with capital of at least VND 12,000 billion or revenue of VND 20,000 billion, with lower thresholds for semiconductors and AI data centres and VND 3,000 billion for research centres. Applications are made by 10 July of the year following the financial year. Groups below the EUR 750 million threshold keep the full value of the incentive.

Import duty, land and start-up incentives

Under Article 16 of Law No. 107/2016/QH13, goods imported to create the fixed assets of an incentivised project, including machinery, equipment, specialised vehicles, components and building materials not produced domestically, are exempt from import duty, for new and expansion projects, on the basis of an exempt-goods list notified to customs before import. Raw materials, supplies and components not available domestically are exempt for five years from the start of production for projects in specially incentivised sectors or especially disadvantaged areas, but not for mining. Export processing enterprises and goods in non-tariff zones have their own exemptions. Land rent exemptions run from the construction period (up to three years) through incentive periods of 3, 7, 11 or 15 years, or the whole term, by sector and location under the Land Law decrees, and are recorded in the land lease.

Resolution No. 198/2025/QH15 on private economic development gives newly established small and medium-sized enterprises a three-year CIT exemption from first registration and innovative start-ups two years' exemption followed by a 50% reduction for four years, with personal income tax relief for certain experts and scientists. Law No. 71/2025/QH15 on the Digital Technology Industry, effective 1 January 2026, treats semiconductor, key digital technology product, AI data centre and innovative start-up projects as specially incentivised and permits regulatory sandboxes. Decree No. 320/2025/ND-CP allows an enhanced deduction for qualifying research and development spending, and enterprises may set aside up to 20% of pre-tax profit for a science and technology development fund.

How incentives are claimed

1. Identify the groundSector, location, scale or special incentive, against the lists in Decree No. 96/2026/ND-CP and, for CIT, the lists in Law No. 67/2025/QH15 and Decree No. 320/2025/ND-CP. Where more than one ground applies, the most favourable governs.
2. Record itWhere the project has an IRC or investment policy approval, the incentives and their legal basis are stated in it. Where it has neither, the investor determines its own eligibility and is responsible for the assessment.
3. Claim CIT incentives in the returnThe company applies the preferential rate and holiday in its quarterly provisional payments and annual finalisation, keeps separate accounts for incentivised income, and retains the evidence that the sector or location conditions are met each year.
4. Claim duty exemptions through customsNotify the exempt-goods list to the customs office before the first import; declare the exemption on each import declaration; keep the goods in use for the project (sale or re-purpose triggers duty).
5. Claim land relief through the land authorityApply for the land rent exemption or reduction when the lease is signed; the land authority records it and issues the rent notices accordingly.
6. Keep qualifyingConditions apply throughout the incentive period. Loss of high-tech status, relocation, failure to disburse capital on the schedule, or a change of objectives ends the incentive from that point, and amounts wrongly claimed are recovered with late-payment interest of 0.03% a day.