Scenario: a Singaporean logistics firm wants a 12-hectare hub in Thanh Hoa serving the Nghi Son refinery-petrochemical cluster and port, weighing a site inside the Nghi Son economic zone against a difficult mountainous district nearby. Which yields the better incentive basket?
The incentive frame: new laws, unchanged principles
The Law on Investment 143/2025/QH15 (effective 1 March 2026, replacing Law 61/2020/QH14) provides in Articles 15 and 16 for corporate income tax incentives, land-rent and land-use-fee relief, and investment support. The Law on Corporate Income Tax 67/2025/QH15 (effective 1 October 2025) sets the standard 20% rate; 15% for annual revenue up to VND 3 billion, 17% for revenue over VND 3 billion to VND 50 billion; and a 10%-for-15-years frame — four-year holiday plus 50% reduction for nine further years — for encouraged-sector projects.
Decree 31/2021/ND-CP supplies the encouraged-sector and location schedules — issued under the 2020 Law on Investment but still cited until replaced. Decree 103/2024/ND-CP governs land-use-fee and land-rent relief. Since Law 67/2025, an industrial-park location no longer automatically qualifies a project for tax incentives; but in-zone projects enjoy incentives under the zone’s own mechanism.
Thanh Hoa: two location pillars for a logistics project
Thanh Hoa offers two location pillars at once. First, the Nghi Son economic zone — a coastal zone built around refining, petrochemicals, deep-sea port and heavy industry; an in-zone logistics project enjoys CIT incentives and land-rent relief under the zone mechanism, regardless of whether pure logistics is an encouraged sector. Second, the western mountainous districts classified as difficult or especially difficult — a project there (even outside the zone) may earn difficult-area incentives.
Unlike Hai Phong (a container-port zone), Nghi Son serves heavy industry, bulk cargo and refinery flows — specialised warehousing and oversized-cargo transport. The basket of a 12-hectare in-zone hub — if conditions are met — includes zone-mechanism tax incentives, long-term land-rent relief under Decree 103/2024 and zone policy, plus board support. The mountainous-district option trades this for difficult-area incentives, offset by distance from port and customers.
Choosing the tier, and the global minimum tax warning
Article 15 of the Law on Investment bars two same-type tax incentives at the same time; the investor picks the most favourable tier. Where a project sits both inside the zone and in a difficult area, compare the tax frames and take one best frame per income stream, then layer the different types: tax, land rent, support.
The mandatory warning for large groups: Resolution 107/2023/QH15 and Decree 236/2025/ND-CP apply a minimum top-up tax from 1 January 2024 to groups with consolidated revenue above EUR 750 million. A low in-zone rate at Nghi Son may trigger top-up tax at group level, shrinking the real value of the rate incentive. Model this scenario and prioritise less-exposed forms such as long-term land-rent relief.
Checklist for a Thanh Hoa project
Confirm the Nghi Son zone boundary and the site under the approved master plan; verify zone-mechanism eligibility with the Nghi Son Economic Zone Authority; if considering a mountainous district, check the current difficult-area list; lock land-rent relief under Decree 103/2024; assess the global minimum tax impact at group level; record incentives in the Investment Registration Certificate and self-declare at annual finalisation.
1. What does an in-zone Nghi Son logistics project get?
If conditions are met, in-zone projects enjoy CIT incentives and land-rent relief under the zone mechanism — independent of the encouraged-sector list.
2. How does Nghi Son differ from Dinh Vu–Cat Hai for logistics?
Nghi Son serves refining, deep-sea port and heavy industry — bulk and oversized cargo; Dinh Vu–Cat Hai serves container flows. Zone incentive mechanics are similar, but service demand and customers differ.
3. Is a mountainous Thanh Hoa district better?
It may earn difficult-area incentives, but weigh higher transport costs from distance to port and customers; decide on total after-tax cost.
4. What should a global group note on the minimum tax?
Above EUR 750 million in consolidated revenue, the top-up tax applies from 1 January 2024 (Resolution 107/2023/QH15, Decree 236/2025/ND-CP); a low rate may trigger top-up tax.
5. Which authority handles Nghi Son incentives?
The Nghi Son Economic Zone Authority confirms the in-zone location and zone-mechanism eligibility.
This article has been quality-reviewed by the FLAW AI Legal Council