When Vietnam adopted the global minimum tax, large multinational groups discovered that traditional CIT incentives are partly neutralised: tax forgiven in Vietnam can be topped up in the home country. The Investment Support Fund was created to answer this problem — shifting from letting investors keep tax money to directly supporting, in cash, the costs enterprises actually incur: training, R&D and initial investment.
The fund mechanism: support for real costs, not tax exemption
The Investment Support Fund is regulated by Decree 182/2024/ND-CP, formed from the state budget to support enterprises and projects in strategic priority fields. Unlike tax incentives (reduced payment obligations), fund support is post-investment cost financing: the enterprise spends first on eligible items, completes the evidence dossier and receives support at prescribed ratios. Support amounts are not counted as corporate income tax taxable income.
This design has two important consequences for groups under the global minimum tax: cost support is not neutralised by the minimum-tax mechanism the way tax exemptions are, and it attaches to substantive activity (real people trained, real R&D, real assets) — exactly what industrial policy wants to buy, instead of buying paper presence.
Support items and maximum levels
Under Decree 182/2024, the main support items are: workforce training and development support up to 50% of costs; research and development support up to 30% of costs; fixed-asset investment support up to 10% of costs; hi-tech product manufacturing support up to 1%; and social infrastructure investment support up to 25%. A special group: R&D centre projects in semiconductors and artificial intelligence meeting conditions receive initial investment cost support of up to 50%.
Matching scale conditions apply: an eligible R&D centre must reach minimum total investment capital of VND 3,000 billion and disburse at least VND 1,000 billion within the first three years. The specific support level per project is decided on the registration dossier within the fund’s budget limits for each period — this is an approval mechanism, not an automatic formula entitlement.
Who qualifies: strategic, hi-tech and key supply-chain projects
The fund targets hi-tech enterprises, hi-tech product manufacturing projects, R&D centres and projects in strategic fields such as semiconductors and artificial intelligence, together with large spillover projects under the special investment support regime. A mid-sized FDI enterprise in ordinary manufacturing is not in the fund’s central group — expectations must be set correctly.
Practical approval factors include: capital scale and disbursement commitments; technology content and R&D activity in Vietnam; training plans and high-skill labour use; and the project’s position in national strategic supply chains. The support registration dossier should be built in parallel with the investment dossier, because the support decision ties to the project’s cost structure from design stage.
Incentive strategy in the new era: from claiming tax to designing costs
For groups under the global minimum tax, the optimisation problem is no longer the lowest tax rate but the combined package: how much tax incentive survives the top-up mechanism, fund support for which cost items, and land and infrastructure incentives at the location. Project negotiation teams must model all three layers before fixing location and cost structure.
The key mindset shift: because support attaches to real costs, the project structure should maximise eligible cost items in Vietnam (placing training and R&D centres onshore instead of outsourcing abroad) — a lawful and far more durable lever than pure tax optimisation techniques in the post-global-minimum-tax environment.
Frequently Asked Questions
Which costs does the Investment Support Fund support?
Under Decree 182/2024/ND-CP: workforce training and development; research and development; fixed-asset investment; hi-tech product manufacturing; and social infrastructure investment. Qualifying semiconductor/AI R&D projects also receive initial investment cost support at the highest level. Support is excluded from CIT-taxable income.
Which FDI enterprises qualify for support?
The central group is hi-tech enterprises, hi-tech product projects, R&D centres and strategic projects (semiconductors, AI), plus large projects under the special support regime — with scale thresholds, for example an R&D centre needs minimum capital of VND 3,000 billion and disbursement of at least VND 1,000 billion in three years. Mid-sized ordinary manufacturers are not the fund’s priority group.
What are the maximum support levels and the application procedure?
Ceilings by item: training up to 50% of costs, R&D up to 30%, fixed assets up to 10%, hi-tech product manufacturing up to 1%, social infrastructure up to 25%; semiconductor/AI R&D may receive initial investment cost support up to 50%. Procedure: register support with the project dossier and eligible-cost evidence; the competent authority appraises and decides within the fund’s budget.
Should incentive strategy shift from tax reduction to direct support?
For groups under the global minimum tax: yes — because tax forgiven in Vietnam may be topped up at home, while cost support is not neutralised in the same way. The optimal strategy models the combined package (surviving tax incentives plus fund support plus land incentives) and structures the project to maximise eligible Vietnam costs such as onshore training and R&D.
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