This guide is part of the VIFC talent and residency pathway, which explains the dual-hub framework, legal instruments, work authorization, tax and family routes.
VIFC tax guide
VIFC tax exemption under Decree No. 324/2025/ND-CP
A source-bounded guide to the Vietnamese PIT exemption for qualifying managers, experts, scientists and individuals with high professional qualifications, the confirmed end-2030 boundary and the issues requiring individual tax advice.
Direct answer
Article 7(2)(a) of Decree No. 324/2025/ND-CP gives a PIT exemption to qualifying managers, experts, scientists and individuals with high professional qualifications working at the International Financial Center on salary and wage income earned from work there through end-2030. Article 7(2)(b) separately addresses certain transfers to IFC members.
This is general information, not legal or tax advice. Regulations at the VIFC are new and evolving — confirm current requirements with a licensed professional.
What the exemption does — and does not yet answer
Decree No. 324/2025/ND-CP creates a defined Vietnamese personal income tax benefit for a defined group. It covers qualifying managers, experts, scientists and individuals with high professional qualifications working at the International Financial Center, and it applies to salary and wage income earned from work at the International Financial Center until the end of 2030. The decree was issued on 18 December 2025 and took effect on 17 January 2026.
That core rule is narrower than a general promise of tax-free employment. The confirmed facts do not resolve how an individual is classified as a qualifying manager or expert, how work is evidenced as being within the centre, or how mixed duties and mixed income should be allocated. They also do not establish the treatment of equity compensation, income earned outside the centre, payroll mechanics, withholding, tax residence, treaty relief, filing duties, or the position after 2030. Each of those points should remain expressly open until verified.
VIFC is one legal entity with Ho Chi Minh City and Da Nang hubs, a separate regulatory zone alongside Vietnamese law, and a one-stop Executive Agency. These features do not expand the confirmed tax exemption.
| Question | Confirmed position | Boundary or action |
|---|---|---|
| Who may qualify? | Qualifying managers, experts, scientists and individuals with high professional qualifications working at the International Financial Center. | See open questions below. |
| Which income is covered? | Salary and wage income earned from work at the International Financial Center. Article 7(2)(b) separately addresses certain transfers to IFC members. | Treatment of bonuses, equity and other amounts requires item-specific review. |
| Where must the income be earned? | Within the centre, which is one legal entity with Ho Chi Minh City and Da Nang hubs. | See open questions below. |
| What work connection is required? | Article 7(2)(a) uses the ‘working at the International Financial Center’ connection. | Treatment of secondments, dual contracts, group payrolls, contractors and non-member entities requires confirmation. |
| How long does the exemption last? | Until the end of 2030. | See open questions below. |
| What is the legal authority? | Decree No. 324/2025/ND-CP, issued 18 December 2025 and effective 17 January 2026. | See open questions below. |
Decree No. 324/2025/ND-CP
This exemption is anchored to Decree No. 324/2025/ND-CP rather than an informal incentive. The decree was issued on 18 December 2025 and took effect on 17 January 2026. Its confirmed effect for this page is that qualifying managers, experts, scientists and individuals with high professional qualifications working at the International Financial Center are exempt from personal income tax on salary and wage income earned from work at the International Financial Center until the end of 2030.
Article 7(2)(b) separately provides PIT relief through the end of 2030 for individuals earning income from the transfer of shares, contributed capital or rights to contribute capital to IFC members, but excludes income from transfers of shares or rights to buy shares of public companies and listed or traded organisations under securities law. This is transaction-specific relief, not blanket capital-gains relief; confirm the asset, parties and conditions before relying on it.
Article 7(2)(c) requires the Article 7(2)(a) group to have 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 eligible people; assess each case individually.
The reference should stay close to that exact proposition. It should not be used to imply that every employee of an IFC member qualifies, that all compensation is covered, or that an exempt amount is automatically excluded from every payroll or filing process.
VIFC is one legal entity with two hubs, a separate regulatory zone alongside Vietnamese law, and a one-stop Executive Agency. This page should not imply that the zone displaces Vietnamese tax law.
Key boundaries for executive planning
Senior hires and employers should separate the confirmed exemption from the unanswered implementation questions before agreeing a net-pay position, compensation package, mobility policy, or assignment structure.
- Qualifying role: The confirmed category is qualifying managers, experts, scientists and individuals with high professional qualifications working at the International Financial Center. A job title alone should not be presented as sufficient.
- Income character: The confirmed income categories are salary and wage income earned from work at the International Financial Center. Equity compensation and other forms of remuneration remain outside the confirmed facts.
- Work inside and outside the centre: The exemption is tied to salary and wage income earned from work at the International Financial Center. The treatment of duties performed elsewhere is not confirmed.
- Work connection: Article 7(2)(a) uses the ‘working at the International Financial Center’ connection. IFC-member status remains relevant where a separate provision expressly requires it, such as Article 7(2)(b) transfers or the immigration route.
- Payroll, withholding and filing: An income-tax exemption does not, on the available facts, answer how payroll should report covered pay or whether withholding and filing steps still apply.
- Tax residence and treaty position: Vietnamese tax residence, home-country residence and treaty outcomes are not established by the exemption alone.
- End of the incentive period: The confirmed exemption lasts until the end of 2030. No post-2030 treatment should be inferred.
Home-country tax can change the total outcome
The Vietnamese exemption describes only the confirmed Vietnamese treatment within its stated scope. An executive’s overall result can differ because tax residence and applicable treaties determine the total outcome.
US-connected executives: Tax residence and applicable treaties determine the total outcome for a US-connected executive. This page does not state whether any income is reportable, taxable, creditable, excludable, or exempt in the United States. Ask a tax adviser to review the individual’s residence and treaty position before relying on the Vietnamese exemption in a total-tax estimate. Ask a US and Vietnam tax adviser to review your position.
UK-connected executives: Tax residence and applicable treaties determine the total outcome for a UK-connected executive. This page does not state whether any income is reportable, taxable, creditable, or exempt in the United Kingdom. Ask a tax adviser to review the individual’s residence and treaty position before relying on the Vietnamese exemption in a total-tax estimate. Ask a UK and Vietnam tax adviser to review your position.
EU-connected executives: Tax residence and applicable treaties determine the total outcome for an EU-connected executive. This page does not treat the European Union as a single personal tax jurisdiction or state a result for any member country. Ask a tax adviser to review the relevant country residence and treaty position before relying on the Vietnamese exemption in a total-tax estimate. Ask an adviser covering the relevant EU country and Vietnam to review your position.
Planning for income paid or earned after 2030
The confirmed exemption runs until the end of 2030. This page should not say that it continues, renews automatically, ends without transition, or applies to later payments linked to earlier work. Those outcomes have not been established in the approved facts.
Executives negotiating multi-year arrangements should flag compensation events that may occur near or after the end of 2030.
Post-2030 treatment is not yet stated on this page. Follow the maintained guide for verified legislative, transitional, or renewal information.
Information to assemble for an individual review
The following checklist is designed to frame questions, not to predict eligibility or tax treatment.
- Role description and reporting line. See open questions below.
- Identity of the employing or engaging entity. See open questions below.
- Expected work pattern across the Ho Chi Minh City hub, Da Nang hub, other Vietnam locations, and locations outside Vietnam. See open questions below.
- Complete compensation schedule separating salary and wage income, allowances, benefits, deferred amounts, equity-related items and variable payments, with every category not confirmed by Article 7(2)(a) identified for separate review. See open questions below.
- Proposed payroll and payment chain, including any offshore or group entity involved. See open questions below.
- Expected arrival, departure, travel, and work dates. See open questions below.
- All compensation events extending beyond 2030. See open questions below.
Open questions
What is not yet settled
These points require confirmation against current guidance and the facts of an individual case
- Not yet confirmed: whether the Executive Agency has any formal role in tax-status confirmation, payroll administration, withholding coordination, or supporting documentation.
- Not yet confirmed: the legal definitions, qualification tests, evidence requirements, and approval or recognition process for manager and expert status.
- Not yet confirmed: the treatment of allowances, benefits in kind, signing or retention payments, severance, deferred compensation, carried interest, equity awards, options, restricted shares, and share-sale proceeds.
- Not yet confirmed: how work location is determined and documented, including travel, remote work, duties performed outside either hub, and time split across locations.
- Not yet confirmed: how the Article 7(2)(a) working-at-the-International-Financial-Center connection is evidenced, and the treatment of group companies, secondments, professional employer arrangements, non-member entities and third-party engagements.
- Not yet confirmed: the final covered earning period, any transition rule, and all treatment applying from 1 January 2031.
- Not yet confirmed: the decree articles and clauses that support the eligibility, income-scope, territorial-scope, effective-date, and end-date statements used on this page.
- Not yet confirmed: obtain counsel-approved language explaining the interaction between the VIFC regulatory zone, general Vietnamese tax law, and any implementing guidance.
- Not yet confirmed: role definitions, required credentials or experience, responsible authority, application steps, documentary evidence, and whether qualification can be confirmed before employment begins.
- Not yet confirmed: the Vietnamese tax characterization and exemption treatment of each compensation component in the proposed package, including grant, vesting, exercise, payment, sale, deferral, and cancellation events where relevant.
- Not yet confirmed: whether and how income must be allocated across VIFC and non-VIFC duties, what allocation method is accepted, and which records should substantiate location and activity.
- Not yet confirmed: which entity must be the legal or economic employer and how changes in VIFC membership affect eligibility.
- Not yet confirmed: payroll coding, withholding treatment, employer reporting, employee registration, annual or departure filing, refund procedures, certificates, deadlines, record retention, and the office or authority responsible.
- Not yet confirmed: determine the individual’s residence position for each relevant period, identify any applicable treaty, confirm treaty access and tie-breaker analysis where relevant, and document foreign tax credit or exemption treatment.
- Not yet confirmed: whether extension, expiry, grandfathering, apportionment, payment-timing, vesting-timing, or transition provisions apply after 2030.
- Not yet confirmed: the governing timing rule for wages, bonuses, deferred compensation, and equity-related events, together with any transition or grandfathering provisions.
Questions senior candidates ask
VIFC pathway FAQ
Who qualifies for the VIFC personal income tax exemption?
The confirmed scope covers qualifying managers, experts, scientists and individuals with high professional qualifications working at the International Financial Center. The available facts do not define those roles or explain how status is established. A page, employer, or candidate should not infer qualification from seniority or title alone.
Does the exemption cover salary, bonuses and equity compensation?
It covers salary and wage income earned from work at the International Financial Center until the end of 2030. Equity compensation is not confirmed. Other remuneration should not be grouped into the exemption without item-specific analysis.
What happens if I work partly outside the VIFC?
The confirmed exemption is for salary and wage income earned from work at the International Financial Center. The approved facts do not state how mixed-location or mixed-duty income is treated.
Will payroll stop withholding Vietnamese personal income tax automatically?
The exemption does not, on the available facts, establish an automatic payroll result. Withholding, payroll reporting, individual filing, refunds, certificates and documentation remain unconfirmed.
Does the exemption eliminate tax in my home country, and what happens after 2030?
No total outcome should be inferred. Tax residence and applicable treaties determine the home-country result. The confirmed Vietnamese exemption lasts only until the end of 2030, and post-2030 treatment is not established here.