Decree No. 324/2025/ND-CP

Plain-English summary

Decree No. 324/2025/ND-CP is the tax instrument in the supplied VIFC legal map. It was issued on 18 December 2025 and took effect on 17 January 2026. Its confirmed personal income tax measure applies to qualifying managers, experts, scientists and individuals with high professional qualifications working at the International Financial Center and covers salary and wage income earned from work at the International Financial Center until the end of 2030.

That proposition is specific. It identifies the covered person categories, two income pathways, a centre connection and an end boundary. It should not be restated as tax-free status for every foreign employee, every worker at the IFC or every form of compensation.

The VIFC is one legal entity operating through Ho Chi Minh City and Da Nang hubs. It is a separate regulatory zone alongside Vietnam’s existing legal system. Those structural facts do not broaden the tax measure beyond its confirmed wording.

A defensible case analysis should test each element independently and mark unsupported definitions or mechanics for confirmation.

Key provisions for foreign professionals

Instrument scope: Decree No. 324/2025/ND-CP concerns tax and was issued on 18 December 2025 and took effect on 17 January 2026. Decree 325 (labour, employment, social security) and Decree 327 (entry, exit, residence) are the talent/immigration instruments. Neither should be attributed to the tax decree.

Eligible people: the confirmed categories are qualifying managers, experts, scientists and individuals with high professional qualifications. The reviewed official materials do not define the categories or state how status is established.

Qualification criteria: Article 7(2)(c) refers to a university degree or higher or a prestigious professional certificate recognised by an international professional organisation, plus relevant experience or qualifying senior-management experience. The Executive Agency sets specific criteria and the Chairman identifies or selects eligible people; a title alone is not enough.

Work connection: Article 7(2)(a) uses the ‘working at the International Financial Center’ connection. The source does not explain group-company, secondment, contractor or third-party arrangements.

Income scope: Article 7(2)(a) covers salary and wage income earned from work at the International Financial Center. Article 7(2)(b) separately addresses certain transfers to IFC members. Neither rule should be extended to allowances, benefits, equity, carried interest, investment returns, severance or other amounts without item-specific support.

Centre connection: the salary and wage income must be earned within the centre. The reviewed official materials do not define how location, duties or allocation are determined across the two hubs and work elsewhere.

Time boundary: the confirmed exemption runs until the end of 2030. No extension, grandfathering, transition or post-2030 result is supplied.

What Decree 324 does not answer on the reviewed official materials

The verified facts do not establish payroll, withholding, registration, reporting or filing mechanics. An exemption from personal income tax should not be presented as an exemption from every administrative step.

They do not establish Vietnamese tax residence, home-country tax, treaty access, foreign tax credits or the total cross-border result.

They do not establish treatment of compensation other than salary and wage income under Article 7(2)(a). Article 7(2)(b) separately addresses certain transfers to IFC members, subject to its exclusion for public or listed-company share transactions. Any package containing bonuses, equity or deferred amounts requires item-by-item analysis.

They do not establish allocation for duties outside the centre, remote work, travel or mixed functions.

They do not establish immigration status, a work permit, a work-permit exemption, UD1 residence, UD2 family residence or permanent residence. Decree No. 324/2025/ND-CP is tax-only within the supplied map.

No provision number, form, fee, procedure or administrative timeframe is supplied and none should be inferred.

Change-log stub

Current verified baseline: Decree No. 324/2025/ND-CP was issued on 18 December 2025 and took effect on 17 January 2026, concerns tax measures and provides the stated PIT exemption until the end of 2030 for qualifying managers, experts, scientists and individuals with high professional qualifications working at the International Financial Center on salary and wage income earned from work at the International Financial Center.

Future reviews should identify the instrument, publication and effective dates, affected proposition and operational consequence. Keep a later administrative interpretation separate from an amendment to the decree itself.

Source maintenance remains open.

Decision checklist

If relying on Article 7(2)(b), identify the exact IFC member, transfer instrument and asset. For Article 7(2)(a), map the individual’s role and working-at-the-International-Financial-Center connection. Do not rely only on an office location, shared group brand or planned membership.

Classify the individual as a manager, expert, scientist or person with high professional qualifications only under the applicable legal standard. A job title should not replace the definition.

List every compensation component separately. Mark salary and wage income earned from work at the International Financial Center as the Article 7(2)(a) category; record any Article 7(2)(b) transfer separately. Send bonuses, equity and every other amount for specific review.

Map where and for what duties the compensation is earned. If work crosses hubs, takes place elsewhere or combines activities, do not assume full coverage.

Record the end-of-2030 boundary and avoid projecting the exemption beyond it.

Ask payroll and advisers what reporting, withholding and filing remain necessary despite the exemption.

Review Vietnamese residence, treaty and home-country consequences separately. The VIFC exemption describes only the confirmed Vietnamese measure within its scope.

Keep immigration and work authorization in separate workstreams under the relevant labour and immigration instruments (Decree 325 for employment, Decree 327 for residence). Do not use a tax conclusion as proof of residence or permission to work.