Following the merger, Ho Chi Minh City is Vietnam’s largest recipient of foreign investment and also its most varied business environment: the financial and services centre of the former HCMC, the manufacturing heartland of the former Binh Duong, and the seaport and oil-and-gas cluster of the former Ba Ria – Vung Tau. Three very different business models, producing three different sets of tax issues — now all administered by a single city tax department.
TrustlineAX Advisory provides accounting, tax and compliance services to FDI companies operating in Ho Chi Minh City — from service and trading companies in the central districts, to plants inside industrial parks, to businesses in the port and logistics chain.
The FDI landscape in Ho Chi Minh City after the merger
Effective 1 July 2025, under Resolution No. 202/2025/QH15 of the National Assembly, Binh Duong province and Ba Ria – Vung Tau province were merged into Ho Chi Minh City. The merged city covers 9,888.91 km² with a population of over 14 million — the only locality in Vietnam with more than 10 million residents.
Capital inflows rose sharply after the merger: FDI into the city reached approximately USD 8.37 billion in 2025, and the first four months of 2026 alone attracted close to USD 3.3 billion, up more than 107% year on year. By the end of the first seven months of 2026 the city had achieved nearly 90% of its annual FDI target.
What matters practically for companies is the breadth of the territory. A foreign group can now have its management office in the central area, its plant in the former Binh Duong, and its warehousing near the port in the former Ba Ria – Vung Tau — all within one city. That changes how several things are handled: allocating tax obligations between head office and dependent units, where each unit registers and files, and how location-based CIT incentives are assessed.
Note: the figures above are compiled from publicly published sources as at August 2026 and may change with each reporting period.
Tax administration after the merger
Under Decision No. 1378/QD-CT dated 30 June 2025, from 1 July 2025 the territory is administered by the Ho Chi Minh City Tax Department with 29 subordinate base-level tax units — the largest number of any province or city. Companies based in the former Binh Duong or Ba Ria – Vung Tau areas should confirm which unit now handles their file, and review the address shown on the Enterprise Registration Certificate, Investment Registration Certificate, e-invoice templates and social insurance records.
Accounting and tax issues specific to FDI companies in Ho Chi Minh City
Because the territory now combines services, manufacturing and port activity, the range of tax issues here is wider than elsewhere. What is new after the merger is that many companies are dealing for the first time with a multi-site structure inside a single city:
| Common operating profile in Ho Chi Minh City | Accounting and tax issues to watch |
|---|---|
| Management office in the centre, with plant and warehousing in the former Binh Duong and Ba Ria – Vung Tau areas | Allocating VAT and CIT obligations between head office and dependent units; registering and filing with the correct base-level tax unit; a consistent e-invoice set-up across the whole business |
| Service, consulting, financial and technology companies paying fees to an offshore parent | Foreign contractor tax on management fees, technical service fees, royalties and software fees; evidence that the service was genuinely rendered and benefited the Vietnamese entity |
| Manufacturing plants and export processing enterprises in industrial parks | VAT refund conditions on exports and bank payment evidence; consumption norm management and customs finalisation; CIT incentives by location and sector |
| E-commerce and platform businesses buying advertising from foreign suppliers | Determining the obligation to withhold and pay contractor tax on behalf; distinguishing cases where the foreign supplier already files through the e-portal; deductibility where the document is not a Vietnamese VAT invoice |
| Logistics, warehousing and port services around the Cai Mep – Thi Vai area | The VAT rate applying to each service connected to exported goods; foreign contractor tax on international freight; documentation supporting the 0% rate |
| Subsidiaries of multinational groups with substantial intercompany transactions | Transfer pricing documentation under Decree 255/2026/ND-CP (from the 2026 CIT period): Master File, Local File and Country-by-Country Report; the 30% EBITDA cap on deductible interest |
| Administrative merger effective 1 July 2025 | Updating addresses on registration records, e-invoice templates and social insurance files; identifying the correct unit among the 29 base-level tax offices |
Further reading directly relevant to these issues:
- Buying ads from foreign suppliers: when must a Vietnamese company withhold contractor tax?
- Vietnam cuts PIT and CIT by 30% for 2026 and 2027: who qualifies?
- Accounting and tax services for FDI companies in Hanoi
Services we provide in Ho Chi Minh City
1. Accounting and parent company reporting
- Bookkeeping under Vietnamese Accounting Standards (VAS) and annual financial statements for the statutory audit
- Monthly management reporting in English in your group’s format, ready for consolidation
- Consolidating figures across the head office and dependent units in different locations
- Reconciliation between VAS and IFRS or your parent company’s framework where required
2. Tax management for multi-site structures
- Determining and allocating VAT and CIT obligations between head office and dependent units
- Registering and filing with the correct base-level tax unit after the territorial merger
- Standardising the e-invoice set-up across all branches and business locations
- Reviewing the CIT incentives applying to each project location
3. Foreign contractor tax and cross-border transactions
- Reviewing service, royalty, software and loan agreements with offshore parties to determine FCT exposure
- Determining the withholding obligation when buying services from foreign suppliers through e-commerce platforms
- Building the evidence file showing services were genuinely rendered — decisive when the tax authority examines payments to a parent company
- Applying double taxation agreements where the conditions are met
4. VAT refunds and import-export compliance
- Reviewing VAT refund eligibility before the claim is filed, with particular attention to bank payment evidence
- Preparing refund claims and responding to tax authority queries
- Reconciling customs declarations against the general ledger and supporting customs finalisation
5. Payroll, expatriates and transfer pricing
- Payroll processing, PIT withholding and compulsory insurance filings
- Tax residency determination and PIT finalisation for expatriates; work permits and temporary residence cards
- Preparing the related-party declaration appendices filed with the annual CIT finalisation, and assessing whether the company is exempt from the Local File and Master File
- Risk assessment and adjustment planning ahead of the annual finalisation
How we work with companies in Ho Chi Minh City
For companies in Ho Chi Minh City we work primarily through electronic document workflows and scheduled video meetings, combined with on-site attendance arranged in advance — typically at key points such as year-end stocktakes, records handover, or during a tax inspection. A typical engagement runs as follows:
- Initial review — the Investment Registration Certificate, Enterprise Registration Certificate, the list of branches and business locations, current filing status and incentives claimed
- Handover and data clean-up — taking over existing records, clearing backlogs, aligning the chart of accounts and reporting templates with the group
- Ongoing operation — bookkeeping and filing to deadline for the head office and each dependent unit, with bilingual monthly reporting
- Pre-finalisation review — foreign contractor tax exposure, transfer pricing documentation, refund eligibility and incentive conditions before the year-end close
- Ad hoc support — liaison with tax and customs authorities, and coordination with your independent auditor and group advisers
Frequently asked questions
Where do companies in the former Binh Duong or Ba Ria – Vung Tau areas now file?
Tax codes and legal status are unaffected by the merger. However, from 1 July 2025 the entire territory is administered by the Ho Chi Minh City Tax Department through 29 base-level tax units under Decision No. 1378/QD-CT — the largest number in the country. Companies should identify precisely which unit now handles their file and update the address on registration documents and e-invoice templates.
Head office in the centre, plant in the former Binh Duong — are these still two different locations?
Administratively they are now within one city, but filing obligations are still determined for each dependent unit and the base-level tax office administering it; they do not merge automatically. The allocation of VAT and CIT between head office and dependent units continues to follow the existing rules. Location-based CIT incentives in particular should be reassessed against the specific project file rather than inferred from the territorial merger.
Does a company advertising on foreign platforms have to withhold contractor tax?
It depends on each supplier’s tax registration status. Where the foreign supplier already declares and pays tax through the electronic portal for foreign suppliers, and the documentation shows a price inclusive of Vietnamese tax, the buyer does not withhold. That said, the document the supplier issues is usually not a valid Vietnamese VAT invoice, so input VAT is not creditable — while the cost may still be deductible if the documentation and payment conditions are met.
Do small businesses in Ho Chi Minh City qualify for the 30% tax reduction?
Under Resolution No. 43/2026/QH16, enterprises and organisations established under Vietnamese law with annual revenue not exceeding VND 10 billion in each of 2026 and 2027 receive a 30% reduction of the CIT payable for those periods; resident business individuals within the same threshold receive a 30% PIT reduction. Eligibility is assessed year by year, and an exclusion applies to enterprises formed by division or separation after the Resolution took effect.
How much do accounting services for an FDI company in Ho Chi Minh City cost?
Fees depend on the nature of operations, monthly transaction volume, headcount, the number of branches and business locations, whether related-party transactions exist, whether incentives must be maintained, and whether English-language reporting is required. We quote after reviewing your actual records rather than applying a fixed price list.
Speak with our specialists
If your company operates in Ho Chi Minh City and needs to reorganise its filing obligations after the territorial merger, review foreign contractor tax on payments to a parent company, or appoint an outsourced accounting team that works in English with your group, get in touch for a free 30-minute consultation.
Contact TrustlineAX Advisory →
This page is provided for general reference and does not replace specific advice on an individual company’s records or transactions.