The personal income tax exemption until end-2030 is the most cited incentive when the International Financial Centre recruits foreign experts, and also the one most easily misapplied. Resolution 222/2025/QH15 attaches the exemption to income arising at the IFC of a defined workforce group, not to the entire income of anyone who has ever set foot in the centre.
Scope of the exemption: only salary and wage income arising at the IFC
Under the regime oriented by Resolution 222/2025/QH15, the group exempted from personal income tax until end-2030 comprises managers, experts, scientists and highly qualified personnel working at the IFC. The exempt income is income from salaries and wages arising at the IFC, meaning the portion attached to work performed for an organisation at the centre and paid in connection with the centre’s activity.
This scope limit has two consequences. First, the time mark is end-2030: income arising from 2031 onward returns to the ordinary tax framework even if the expert still works at the IFC, unless a later document extends the regime. Second, the income must be IFC salary or wages; other income of the same individual, such as capital investment income, transfer gains or income from activity outside the centre, sits outside this exemption and may not be stretched out of the talent incentive policy.
Non-IFC income of the same expert is handled separately
The hardest practical case is an expert who works both for an organisation at the IFC and earns income from a unit outside the IFC, for example a consulting contract with the overseas parent company or fees from another enterprise in Vietnam. The non-IFC portion is not exempt, and the payer may not merge it into the IFC payroll to exempt the whole package. Separation must happen at the contract: the labour contract or IFC assignment decision states the work scope and paying source clearly; the non-IFC contract stands independently with its own payment documents.
For an expert who is a Vietnamese tax resident, the year-end finalisation duty still covers all taxable income, with the IFC-exempt portion excluded on the strength of the proof dossier. Neither the enterprise nor the expert should read exemption at source as exemption from all procedures: declaring the exempt and non-exempt components correctly is the condition for the tax authority to accept the treatment on later inspection.
Proof dossier and the payer’s procedure when applying the exemption
The dossier proving income qualifies for exemption has three document layers. Layer one proves the payer’s status: documents confirming the IFC membership of the employing organisation at the centre. Layer two proves the individual’s working relationship at the IFC: the labour contract, recruitment or assignment decision for work at the IFC, with a position description showing the manager, expert, scientist or highly qualified personnel category. Layer three proves the income itself: payroll records, payment documents and finalisation records showing income arising from IFC work in the period until end-2030.
On procedure, the income payer continues to perform withholding and declaration under the Law on Tax Administration 108/2025/QH15 for the taxable portion, and applies non-withholding to the exempt portion on the basis of the proof dossier above. When detailed guidance on the IFC tax exemption is issued, the enterprise must recheck the forms and how the exempt amount is recorded in the return; until then, keeping all three dossier layers complete is the only protection if the exemption is challenged.
Frequently Asked Questions
Within what scope are foreign experts working at the IFC exempt from PIT until end-2030?
The exemption covers salary and wage income arising at the IFC of managers, experts, scientists and highly qualified personnel working at the centre, for the period until end-2030 under Resolution 222/2025/QH15. The incentive attaches to the IFC income source and to the defined workforce group; it does not attach to the individual’s entire income and does not extend automatically beyond 2030.
What proof documents are required to show income falls within the IFC exemption?
The dossier has three layers: documents confirming the payer’s IFC membership; the labour contract or IFC work decision proving the individual belongs to the manager, expert, scientist or highly qualified personnel group; and payment documents showing the income arose from work at the IFC. Missing any one layer makes the income hard to accept as exempt when the tax authority inspects.
Is the same expert’s non-IFC income also exempt?
No. Income arising outside the IFC, including fees from the overseas parent company or from another enterprise in Vietnam, falls outside the exemption scope of Resolution 222/2025/QH15 and is taxed under the ordinary framework. The enterprise must separate contracts and payment documents between the IFC and non-IFC portions; merging the whole package into the IFC payroll to exempt everything is incorrect and carries back-assessment and penalty risk.
What procedure must the paying enterprise follow to apply the exemption for an expert?
The payer continues withholding and declaration under the Law on Tax Administration 108/2025/QH15 for the taxable portion, and applies non-withholding to the exempt portion once it holds the full proof dossier of IFC membership, the IFC working relationship and the income documents. The payer keeps this dossier with the payroll records of the payment period for explanation on request, and updates its recording method when detailed IFC exemption guidance is issued.
Applying the IFC PIT exemption with FLAT Law Firm
FLAT Law Firm helps IFC enterprises structure a foreign expert’s income package along the exact exemption boundary of Resolution 222/2025/QH15: separating the IFC contract from non-IFC contracts, completing the three proof dossier layers and setting up withholding and declaration under the Law on Tax Administration 108/2025/QH15 so the exemption stands up to inspection.
This article has been quality-reviewed by the FLAW AI Legal Council