Made in Vietnam: new rules for a booming factory economy

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Made in Vietnam: new rules for a booming factory economy

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Garment factory in Ho Chi Minh, Vietnam
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As growth hits a four-year high, Bob Tseng and Sally Nguyen of TWL Law Group unpack the reforms that foreign manufacturers and traders need to know

Manufacturing continues to power Vietnam’s rapid economic expansion. National Statistics Office data shows GDP up 9.01% year on year in January–September 2026, with third-quarter growth of 9.95% marking a four-year high. Manufacturing value added rose 11.36%, roughly one-third of total growth. Exports increased 24.5% to $434.3 billion and imports climbed 36.7% to $453.7 billion, bringing two-way goods trade to nearly $888 billion. Registered foreign investment surged 76.4% to $50.4 billion.

Behind these figures lies a wave of investment, tax, labour, and trade reforms designed to cut red tape and strengthen Vietnam’s place in global supply chains, with direct consequences for foreign businesses.

Investment and tax

Market entry is becoming faster. Foreign investors may now obtain an enterprise registration certificate before an investment registration certificate. Decree 96/2026/ND-CP adds fast-track approval for projects in industrial parks, high-tech parks, and free trade zones.

The tax and cost picture is more mixed:

  • A 15% global minimum tax under the OECD’s pillar two rules for multinational groups with consolidated revenue of at least €750 million (Decree 236/2025/ND-CP), which may reduce the value of tax holidays for large investors.

  • Under the Law on Corporate Income Tax 2025:

    • A standard CIT rate that remains 20%;

    • Reduced rates of 15% for eligible enterprises with annual revenue of up to VND 3 billion and 17% for those with revenue above VND 3 billion and up to VND 50 billion, subject to statutory conditions; and

    • A preferential 10% rate for 15 years for qualifying high-tech, R&D, science and technology, and renewable or clean energy activities.

  • An extension of the reduced 8% VAT rate until December 31 2026 (Decree 174/2025/ND-CP).

  • Enhanced incentives for semiconductor, AI, and other digital technology projects (Law on Digital Technology Industry No. 71/2025/QH15).

  • An average 7.2% increase in regional minimum wages, which directly raises labour costs for manufacturers (Decree 293/2025/ND-CP).

Trading: market access and licensing

Trade data show how deeply Vietnam is embedded in regional supply chains. Imports outpaced exports in the first nine months, leaving a goods trade deficit of about $19.4 billion, while foreign-invested enterprises (FIEs) generated around 80.7% of export value.

Market access remains a core advantage. Vietnam’s free trade agreements – including the Comprehensive and Progressive Agreement for Trans-Pacific Partnership, the EU–Vietnam FTA, and the Regional Comprehensive Economic Partnership – give qualifying goods reduced or zero tariffs in major markets. These preferences depend on rules-of-origin compliance, which is drawing closer scrutiny as US trade measures increasingly target trans-shipment. Manufacturers relying on imported inputs should be ready to document the value added in Vietnam.

For FIEs trading goods, the key development is Decree 342/2026/ND-CP, which takes effect on October 18 2026 and replaces Decree 09/2018/ND-CP. FIEs may export, import, and wholesale most goods by registering these activities in their investment or enterprise registration documents. A business licence from the provincial People’s Committee is required only for retail distribution, for goods outside Vietnam’s market-access commitments (such as lubricants, rice, and sugar), and for certain services, including logistics, leasing, commercial intermediation, and e-commerce platforms.

Retail still requires a licence for each outlet, which can be issued together with the business licence for a first outlet in the head-office province. The economic needs test applies only to additional outlets of investors from jurisdictions without treaty commitments abolishing it. Large e-commerce platforms and retail chains above set thresholds also face security review by the Ministry of Public Security and the Ministry of National Defence.

Authorities must assess complete business licence applications within 10 working days, without requesting documents already held in national databases. Existing licences remain valid, and applications filed before October 18 2026 follow the old rules.

Final thoughts

Vietnam’s 2026 reforms point to a lighter-touch, data-driven regulatory model, but the compliance burden has shifted rather than disappeared. Foreign investors should review entry structures, test tax incentives against the global minimum tax, and budget for higher labour costs. Before Decree 342/2026/ND-CP takes effect, trading businesses should confirm that their activities are properly registered or licensed, and exporters that their origin records can withstand scrutiny. Implementing guidance should be monitored closely.

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