Scenario: two factories of one group: one inside an industrial park in a developed province, one outside any park in a mountainous province. The finance team assumes the in-park factory is “naturally” more tax-incentivised. That assumption used to be right — and stopped being right when the Law on Corporate Income Tax 67/2025/QH15 took effect. This article re-compares the whole corporate income tax incentive picture inside and outside industrial parks under current law.
The foundational change: industrial parks left the tax incentive lists
Under the old framework, an investment project in an industrial park (except parks in favourable socio-economic areas) qualified for area-based corporate income tax incentives, with a 17% preferential rate for 10 years, 2 years of exemption and 50% reduction for the following 4 years. The Law on Corporate Income Tax 67/2025/QH15 changed this structure in Article 12: the sector list for preferential rates in clause 2 no longer contains “investment projects in industrial parks”; the preferential area list in clause 3 comprises specially disadvantaged socio-economic areas, disadvantaged socio-economic areas, economic zones, hi-tech parks, hi-tech agriculture zones and digital technology concentrated zones — industrial parks are not on it. In other words, from tax periods under the new law, “inside an industrial park” is no longer an independent incentive ground: a project is incentivised for its sector, or for the disadvantaged area it sits in, or for being in an economic zone or hi-tech park — not for the park fence around it. Transitional rules preserve incentives already granted under the previous regime for their remaining period, so a factory mid-way through a park incentive is not cut off.
The practical comparison table after the new law
Place the configurations side by side. An in-park project in a favourable area versus an outside project in the same area: identical corporate income tax incentives — the standard 20% rate, unless the project belongs to an incentivised sector (which applies at any location) or the enterprise qualifies for the revenue-based rates in Article 11 of Decree 320/2025/ND-CP (15% for enterprises with total revenue not over VND 3 billion, 17% for those not over VND 50 billion, location-independent). A project in an economic zone or hi-tech park: the specific area-incentive frame of those zones (for example a 10% rate for 15 years for projects in economic zones in disadvantaged areas under Article 12). A project outside any park in a disadvantaged or specially disadvantaged area: the corresponding area incentives despite having no park fence — and at the specially disadvantaged rung, the highest incentive frame in the system. Sector incentives (hi-tech, supporting industries, software and the sectors in clause 2, Article 12) apply equally everywhere. The comparison conclusion therefore reverses the old consulting habit: the decisive incentive variables are the administrative area and the sector, while the industrial park is merely an infrastructure choice.
Consequences for location decisions and operating projects
For a new project, the correct analysis order is: determine the incentive frame by the project’s sector first; then compare candidate areas against the current disadvantaged-area list; only then choose inside or outside a park within the chosen area, based on infrastructure, land and supply chains. For an operating in-park project enjoying old-law incentives: review the incentive file now to establish how many transitional years remain, and check the separate-accounting condition for incentivised income — the first thing tax inspectors test at finalisation. For an operating outside-park project in a disadvantaged area that never claimed area incentives: incentives do not apply automatically — the enterprise must self-determine, declare and prove the conditions at finalisation. A final note on other taxes and charges: land-rent incentives (Articles 39 and 40 of Decree 103/2024/ND-CP) run on their own system and are unchanged by this corporate income tax reform — a complete location comparison must add both incentive systems together.
Frequently Asked Questions
How do corporate income tax incentives differ between projects inside and outside industrial parks?
The core difference after the Law on Corporate Income Tax 67/2025/QH15 is that an industrial park location no longer creates an incentive by itself. Clauses 2 and 3, Article 12 of this Law removed ‘investment projects in industrial parks’ from the incentivised sector and area lists — preferential areas now comprise disadvantaged and specially disadvantaged socio-economic areas, economic zones, hi-tech parks, digital technology concentrated zones and hi-tech agriculture zones. Consequently, a project in a park in a favourable area and a project outside a park in the same area bear the same tax (the standard 20% rate, or 15%/17% by revenue scale for smaller enterprises under Article 11 of Decree 320/2025/ND-CP); incentives differ only when the project belongs to an incentivised sector or sits in a disadvantaged area — inside or outside a park alike. Projects already enjoying park incentives under the previous rules keep them for the remaining period under the transitional provisions.
Outside an industrial park but in a disadvantaged area — are incentives equal to those inside a park?
They can be equal or better. Area-based corporate income tax incentives under Article 12 of the Law on Corporate Income Tax 67/2025/QH15 attach to the disadvantaged character of the administrative area and to special functional zones, not to whether an industrial park fence exists: a project outside a park but in a specially disadvantaged socio-economic area receives the highest area-incentive frame (a 10% preferential rate for 15 years with statutory exemption and reduction), while a project inside a park in a favourable area receives no area incentive at all. The correct comparison is pairwise: within the same area, inside and outside a park are identical for tax; across areas, the area decides — not the park.
What conditions must a project outside an industrial park meet to enjoy incentives?
Four cumulative conditions: (1) the project belongs to an incentivised or specially incentivised investment sector list, or is located in a disadvantaged or specially disadvantaged socio-economic area under the current list (Article 12 of the Law on Corporate Income Tax 67/2025/QH15 and guiding instruments); (2) the project content on the Investment Registration Certificate correctly reflects that sector and area; (3) the enterprise can separately account for the incentivised activity’s income (if not, allocation by the prescribed cost criteria applies); (4) the conditions are actually maintained throughout the incentive period — operating per license and at the project location. Missing condition (3) is the most common operational error costing incentives at finalisation even where the project sits in the right area.
Should I choose an industrial park or an outside location if only tax incentives are considered?
If only corporate income tax incentives are considered, after the Law on Corporate Income Tax 67/2025/QH15 the answer is: choose the area and the sector first, and the inside/outside-park question afterwards — because tax no longer rewards the park location. But a location decision never consists of tax alone: a park offers ready infrastructure, simple land procedures via sub-lease, supplier clusters and labour; an outside location offers cheaper land banks, bespoke planning flexibility and — if in a disadvantaged area — markedly higher tax incentives. The right computation models total 10–15-year cost including tax, cyclical land rent, self-invested infrastructure and compliance cost, rather than optimising a single tax.
