Vietnam's IFC: Enacted framework, Incentives & Peer benchmark

Vietnam has moved from pilot-stage discussion to an operational legal regime for its International Financial Center (IFC). The framework is now anchored by a National Assembly resolution and a package of implementing decrees, structured around a "one center, two destinations" model spanning Ho Chi Minh City and Da Nang. For international financial institutions and service providers evaluating Vietnam, this shift matters because it converts what was previously policy intent into an enacted, licensable regime, with defined tax incentives, a differentiated foreign exchange mechanism, and IFC-specific rules that in certain regulated areas now prevail over general Vietnamese law.

From an investor perspective, the IFC design introduces questions that are typical for special regimes:

• How IFC specific rules interact with general Vietnamese law
• The practical operation of licensing and supervision
• The maturity of dispute resolution mechanisms envisaged for IFC users

This report summarizes (1) Vietnam’s stated positioning and hub differentiation, (2) the enacted legal stack at a high level, and (3) a benchmark scorecard for comparing Vietnam’s IFC regime with global IFC archetypes.

1. Policy positioning: Why an IFC, and Why "two hubs"?

Vietnam's IFC initiative is framed as a national effort to build a globally competitive financial services platform under a dedicated regime, accelerating the country's integration into international financial markets. The "one center, two destinations" model is a unified IFC with differentiated positioning for each city, designed to reduce internal duplication and align product focus with each location's comparative advantage.

Ho Chi Minh City	Da Nang
The city is oriented toward a comprehensive financial ecosystem serving the Indochina and Mekong region. Typical focus areas: banking and capital markets; fund/asset management services; fintech and payment infrastructure; professional services ecosystem.	The city is positioned as more niche, tightly integrated with innovation and sustainable finance themes. Typical focus areas: green/sustainable finance; innovation and controlled testing of new models; digital assets and digital payment pilots; trade-linked finance and services.

Implementation planning documentation also points to the development of new markets and innovation rails, suggesting the IFC is expected to support both traditional financial intermediation and newer market platforms.

2. Enacted legal stack

Vietnam's IFC is now supported by a comprehensive, dedicated legal framework, a significant shift from the earlier pilot-stage policy discussions to an operational regulatory regime.

• Resolution No. 222/2025/QH15 (National Assembly): It establishes the legal basis for the "one center, two destinations" model and introduces new mechanisms on investment, taxation, foreign exchange, financial services, labor, dispute resolution and regulatory governance. Importantly, the Resolution allows IFC-specific rules to prevail over Vietnam's conventional legal framework in certain regulated areas, providing greater flexibility and legal certainty for international financial institutions.
• Decree No. 323/2025/ND-CP: establishes the governance framework for the IFC and identifies priority sectors and services.
• Decree No. 324/2025/ND-CP: details the financial policies applicable within the IFC, including tax incentives, capital mobility and operational mechanisms.
• Sector-specific regulations from competent authorities, covering labor, employment and social security, land and environmental management, foreign exchange accounts, and other specialized financial activities.

What this means for financial institutions: together, these instruments now provide the foundational legal infrastructure for licensing, supervision, and day-to-day IFC operations.

3. What activities occur in the IFC?

Vietnam's IFC follows an ecosystem approach: functional zones for trading, banking, securities and related services, supported by institutions including dispute resolution mechanisms designed to be credible to international participants. Implementation planning materials also reference sandbox-style support for fintech, suggesting these areas may be prioritized early.

Because detailed scope still depends on implementing instruments and licensing practice, investors typically assess "activity scope" in three layers:

(1)  Explicitly prioritized sectors:

• IFC infrastructure development
• Green Finance and Environmental, Social, and Governance (ESG)
• Commodity markets, derivatives, and international trade finance
• Fintech and innovation
• Investment funds and asset management services
• Professional support services and other sectors

(2)  Licensable and operationally supported activities:

• Banking and finance
• Securities and investment
• Fintech and digital assets
• Market infrastructure
• Professional services
• Non-financial entities

(3) Practically bankable given compliance and dispute resolution reality: Projects that comply with high-standard Environmental, Social, and Governance (ESG) frameworks and utilize the newly established specialized dispute resolution mechanisms.

4. Incentives and Operating advantages (High level)

A competitive incentive package has been introduced to attract global financial institutions and high-value investment.

Formula highlight, Corporate Income Tax (CIT):

• Priority sectors: preferential CIT rate of 10% for up to 30 years, together with a tax holiday of up to 4 years and a 50% reduction of CIT for up to the following 9 years.
• Outside priority sectors: CIT rate of 15% for up to 15 years, tax holiday of up to 2 years, and a 50% CIT reduction for up to the following 4 years, subject to applicable conditions.

Checklist of other incentives:

• Personal income tax exemption until end-2030 for eligible experts and highly skilled professionals
• Import duty exemptions for eligible technical equipment, software and fixed-asset goods, plus preferential customs procedures and treaty-based tariff preferences
• A more liberal foreign exchange regime for cross-border transactions
• Streamlined one-stop licensing procedures
• Work permits (or exemption certificates) for foreigners valid for up to 10 years, processed within 3 working days
• UĐ1 visas / temporary residence cards (up to 10 years) for eligible foreign investors, experts, managers and highly skilled professionals; UĐ2 visas for accompanying family members; applications processed within 3 working days; long-term key personnel may be considered for permanent residence
• Regulatory sandbox mechanisms to support fintech and other innovative financial services

5. Benchmark considerations with Regional peers

The 38th edition of the Global Financial Centers Index (GFCI), published in September 2025, ranked Ho Chi Minh City #95 out of 120 centers assessed, ahead of Bangkok (#102) and Manila (#104), but behind Jakarta (#91), Labuan (#60), Kuala Lumpur (#45) and Singapore (#4). Da Nang received 53 assessments in the prior 24 months, still short of the 150-assessment threshold required for index inclusion.

The instrumental factors used in the GFCI model are grouped into five broad areas of competitiveness: Business Environment, Human Capital, Infrastructure, Financial Sector Development, and Reputation.

Interestingly, Decision 114/QD-BCDTTTC organizes implementation of Vietnam IFC into five major task groups:

(1) Legal framework

(2) Infrastructure and urban space

(3) Financial services and markets

(4) Human resources and ecosystem

(5) Coordination and supervision

Contrasting with the five factors embedded in GFCI model demonstrates strong areas of overlap, highlighting the targeted approach of the Vietnamese government.

6. Implementation watchpoints

Over the next 24 months, key indicators to track include: (i) issuance of implementing instruments and consistency of guidance, (ii) early licensing outcomes and timelines, (iii) operationalization of dispute resolution institutions, and (iv) evidence of supervisory capacity and cross-agency coordination.

Scenario, lessons from regional IFC peers:

• UAE was placed on FATF's grey list (March 2022) over insufficient AML/CFT enforcement outcomes
• Bahrain's hub status was challenged as unrest prompted banks to relocate staff and assets to perceived-safer Gulf hubs
• GIFT City (India) took more than a decade to gain momentum, tied to policy clarity and a unified regulator (IFSCA)
• Labuan still faces "tax haven" perception risk despite Malaysia's deliberate efforts to avoid the label
• Bangkok International Banking Facility collapsed in the 1990s due to capital management weaknesses, currency/maturity mismatch, and regulatory blind spots

7. Conclusion

In conclusion, implementation of IFC must be carried out effectively, comprehensively and with purpose to avoid regulatory integrity failures and execution foundering. Done right, it can reshape how Vietnam finances growth, manages risk, and positions itself in global capital networks with spillovers into real economy competitiveness and institutional quality.

How can we help?

Contact our Legal and Financial Advisory teams to discuss how Vietnam's IFC regime applies to your institution's Vietnam strategy.