Tax

CIT incentives for foreign-invested logistics and port projects

Quick answer: FDI projects in logistics and seaports can enjoy CIT incentives as encouraged infrastructure investment — especially seaports, inland container depots (ICDs) and logistics centers tied to economic zones and port areas. Incentives include preferential rates, early-year exemptions and 50% reductions thereafter, conditioned on capital scale, progress and location. The key distinction: investing in logistics infrastructure (warehouses, ports, handling systems) differs from pure logistics services (transport, forwarding) — the highest incentives go to infrastructure, not every logistics company qualifies equally.

Applicable legal bases

The framework below is in force as of the writing date (20/10/2026) and directly governs this article:

  • Corporate Income Tax Law 67/2025/QH15 (effective 01/10/2025, applicable from tax year 2025) — CIT incentives for infrastructure projects and projects in economic zones.
  • Investment Law 143/2025/QH15 (effective 01/3/2026) — incentivized business lines and locations; incentives for economic-zone and industrial-park infrastructure.
  • Decree 236/2025/ND-CP (effective 15/10/2025) — guidance on CIT incentives for infrastructure and locationally incentivized projects.
  • Tax Administration Law 108/2025/QH15 (effective 01/7/2026, replacing Law 38/2019/QH14) — incentive registration and filing procedures.

In-depth analysis

Why do logistics and seaports sit in the high-incentive group? Because they are economic infrastructure with spillover effects: a modern seaport cuts logistics costs for the whole region and attracts satellite manufacturing — the state is willing to “share” this benefit through tax incentives. But precisely for that reason, conditions attach tightly to infrastructure character: the project must build works (berths, warehouses, handling systems), meet capital thresholds, and usually sit within port planning or an economic zone. A logistics company merely leasing warehouses and trucks for forwarding services — however large its revenue — is in substance a service business, not an infrastructure project, and does not access the top incentive tier.

Location is the second decisive variable. Seaport and logistics projects inside economic zones (coastal or border-gate economic zones) access the highest locational incentive band — compounding with infrastructure-sector incentives. Projects in ordinary industrial parks get a lower locational band. Projects outside functional zones keep only sectoral incentives (if the project’s logistics line is on the encouraged list). The same dry-port project inside versus outside an economic zone yields two completely different tax outcomes — the location decision must precede tax structuring, not follow it.

Seaport projects carry an additional layer of sectoral conditions: maritime planning and licenses. Seaports are a conditional sector under national seaport planning — projects must conform to planning, hold seaport operation licenses, and meet maritime safety and marine-environment requirements. These are not just investment procedures but preconditions for recognition as an incentivized infrastructure project. Practice shows many foreign investors underestimate the time and cost of this maritime licensing layer, delaying progress and skewing the incentive timeline.

Four factors determining incentives for logistics and port projects

  1. Infrastructure character: building works (berths, warehouses, systems) earns higher incentives than pure logistics services — distinguish clearly in the project dossier.
  2. Project location: inside economic zones the highest band; in industrial parks lower; outside functional zones only sectoral incentives remain.
  3. Capital scale and progress: meeting investment thresholds and disbursement schedules, commissioning on commitment — delays can affect eligibility.
  4. Sectoral licenses: seaport planning conformity, operation licenses, maritime and environmental requirements — parallel preconditions to tax conditions.

Common risks and how to prevent them

  • Assuming all logistics firms get equal incentives: distinguish infrastructure projects from service businesses — correctly assess your group before expecting incentives.
  • Choosing location before modeling tax: model incentives under each location option before deciding — same project, different site, entirely different tax.
  • Underestimating maritime licensing: build sectoral licensing time and cost into the master plan from the start.
  • No activity segregation: projects combining port operation with logistics services — segregate infrastructure and service income in the books.

Frequently asked questions

1. Does a 100% foreign-owned forwarding company get the same incentives as a port project?
No — forwarding and transport are service businesses, not infrastructure investment. Any incentives follow the general framework, far below port and warehouse construction projects.

2. Does an ICD (dry port) count as seaport infrastructure?
An ICD is an inland clearance point tied to the seaport system — if built per planning and meeting infrastructure conditions, it belongs to the incentivized group; check the specific planning and catalogue.

3. Do locational (economic-zone) and sectoral (infrastructure) incentives stack?
Companies choose the most favorable band among those they qualify for; incentives do not stack — but you may choose the optimal frame and switch when qualifying for a higher one.

4. Are foreign investors restricted in seaport ownership ratios?
Seaports are a conditional sector for foreign investors under commitments and investment law — check market-access conditions before structuring, alongside tax modeling.

Key takeaway for investors

Logistics and port incentives reward real infrastructure in the right location. Structure the project as infrastructure (construction, scale, licenses), choose economic-zone sites where possible, and segregate income from day one.

This article has been quality-reviewed by the FLAW AI Legal Council This content is legal reference only and does not replace counsel for a specific case.