Scenario: a Singaporean e-commerce startup wants its marketplace operations hub in Nghe An — choosing between Vinh City and a difficult mountainous district — to optimise costs and capture incentives. Can an e-commerce platform earn investment incentives?
The new e-commerce legal frame from 2026
Before incentives, a marketplace project must comply with the new legal frame: the Law on E-Commerce 122/2025/QH15 and Decree 248/2026/ND-CP — replacing Decree 52/2013/ND-CP from 1 July 2026 — governing registration, notification and responsibilities of e-commerce trading floors. This is the precondition: a non-compliant floor makes every incentive calculation meaningless.
On investment incentives, the Law on Investment 143/2025/QH15 (effective 1 March 2026, replacing Law 61/2020/QH14) provides in Articles 15 and 16 the forms: corporate income tax, land-rent and land-use-fee exemptions or reductions, 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.
E-commerce platforms: sector or location incentives?
A trading platform is not encouraged by default. The sector door opens only if the project meets information-technology or high-tech criteria — e.g. a platform with substantive R&D, data centers, core technology — under Decree 31/2021/ND-CP (cited until replaced). A pure marketplace (matching buyers and sellers) struggles to meet this bar.
The location door is clearer: Nghe An has many mountainous districts classified as difficult or especially difficult. An operations hub there — if conditions are met — earns location-based CIT incentives plus long-term land-rent relief under Decree 103/2024/ND-CP. Compared with Vinh (a developed area: standard rate only, absent sector qualification), the mountainous-district option yields the thicker basket, but must be weighed against telecom infrastructure quality and talent availability.
The selection rule, with a framework illustration
Article 15 of the Law on Investment bars two same-type tax incentives at the same time; the investor picks the most favourable tier. For a marketplace hub in a difficult Nghe An district meeting both technology (sector) and location conditions, compare the tax frames, take one best frame per income stream, then layer the different types.
A framework illustration: an operations hub in an especially difficult district meeting location conditions holds a basket of the location tax frame on operations income, plus long-term land-rent relief under Decree 103/2024. All figures are conditional legal frames, not absolute commitments for any specific project.
Checklist for a marketplace project
Register and notify the floor under Decree 248/2026/ND-CP (replacing Decree 52/2013 from 1 July 2026); assess IT/high-tech criteria under Decree 31/2021; verify the host district is on the current difficult-area list; compare Vinh with mountainous districts on total after-tax cost including digital-infrastructure quality; record incentives in the Investment Registration Certificate; self-declare at annual finalisation.
1. Must a marketplace register under the new rules?
Yes. Under Decree 248/2026/ND-CP (replacing Decree 52/2013/ND-CP from 1 July 2026) implementing the Law on E-Commerce 122/2025/QH15, trading floors must complete registration and notification duties.
2. Is a digital platform automatically tax-incentivised?
No. Only by meeting IT or high-tech criteria; a pure marketplace rarely qualifies on sector grounds.
3. What does a mountainous Nghe An hub get?
If conditions are met: location-based tax incentives for difficult/especially difficult areas plus long-term land-rent relief under Decree 103/2024.
4. How do Vinh and a mountainous district differ?
Vinh is developed: no location incentives, only the sector door (if qualified). A difficult mountainous district adds the location pillar, offset by telecom and talent considerations.
5. Is Decree 52/2013 still in force?
No. Decree 52/2013/ND-CP was replaced by Decree 248/2026/ND-CP from 1 July 2026; all e-commerce filings follow the new frame.
This article has been quality-reviewed by the FLAW AI Legal Council
