Golf courses and casinos are the two components that usually travel together in a large resort complex, and also the two most tightly controlled activities in Vietnamese investment law: golf is locked by land-area caps and prohibited-land lists under Decree 52/2020/ND-CP; a casino exists only inside an integrated service, tourism and entertainment complex with minimum investment capital of USD 2 billion under Decree 03/2017/ND-CP, and must be approved in policy as a casino-containing project before any licence is discussed.
Golf: land caps and conditions under Decree 52/2020
Decree 52/2020/ND-CP sets a hard frame for golf projects: a standard 18-hole course may not exceed 90 hectares (on average no more than 5 hectares per hole); a first-built golf project may not exceed 270 hectares (54 holes); the investor must complete construction within at most 36 months for an 18-hole course and 48 months for others, from the land-lease decision. Land prohibited for golf includes national defence and security land; forest land and rice land (with only a narrow midland and mountainous exception of up to 5 hectares of single-crop rice land, dispersed, meeting rice-land protection conditions); industrial park and cluster land, dike protection zones and coastal protection corridors.
Investor conditions include financial capacity, land-lease and land-use-purpose conversion conditions, an investment security deposit where required, plans and commitments to support resettlement, training and employment for current land users and local labour, and self-provision of transport, power and water infrastructure, wastewater treatment and environmental protection. Appraisal of a golf project policy-approval request under investment law additionally assesses these sector principles and conditions — a golf file is examined in two layers: the general approval layer and the golf-sector layer.
Casinos: alive only inside a USD 2 billion complex, with prior permission
Under Decree 03/2017/ND-CP, casino business is a conditional line under tight control. An investment registration certificate for a casino-containing project is issued only when: competent authority policy approval permitting a project with casino has been obtained; the project is an integrated service, tourism and entertainment complex with minimum components (hotel, service, tourism and commercial areas, entertainment, convention centre); minimum investment capital is USD 2 billion; and a feasible plan exists to control negative impacts. Only after the project has disbursed at least 50% of registered capital does the enterprise meet one of the conditions for the casino Business Eligibility Certificate that allows a casino point to open.
Players at Vietnamese casinos are in principle foreigners and overseas Vietnamese holding foreign passports; Vietnamese residents may play only on a pilot basis at casino points authorised for the pilot (such as Phu Quoc and Van Don), provided the player is 21 or older, has civil act capacity and proves regular income from VND 10 million per month. Nationwide there are currently three large operating casinos (Phu Quoc, Ho Tram, Nam Hoi An) plus a few small points licensed before Decree 03/2017 — the figure shows a casino is not an “apply and receive” line but a high-level policy decision for each specific project.
Incentives and the practical approach for a golf-and-casino resort complex
Tax incentives for a resort tourism project do not follow a separate “casino package”: project parts falling in incentivised sectors or areas (tourism in difficult areas, large-scale projects) enjoy corporate income tax and land-rent incentives under general tax law and incentive lists, while casino operations bear special consumption tax under sector tax rules. The investor financial model must separate cleanly: casino cash flow is locked behind the 50% disbursement milestone and the eligibility certificate, so the complex entire capital schedule should be designed around that milestone.
The practical sequence: fix location and land fund avoiding the golf prohibited-land list; seek policy approval that expressly states the casino component so the project is approved “with casino”; complete investment registration, land, construction and disbursement on schedule; at 50% disbursement with casino-point conditions met, apply for the casino Business Eligibility Certificate. Skipping the “with casino” approval at the start and expecting to add it later is the costliest mistake — a casino cannot be bolted onto an ordinary resort project by a simple amendment procedure.
Golf and casinos are two tests of policy patience: golf land is capped at 270 hectares with a prohibited list, and the casino is locked inside a USD 2 billion complex behind a 50% disbursement milestone. An investor who designs the complex around these locks from the proposal first page can travel the whole road. This draft is pending review by the QA Council.
Frequently asked questions
A foreign investor building a golf course — which approval level applies?
A golf project requires investment policy approval under investment law (deciding level per the devolution of Investment Law 143/2025/QH15), and the appraisal file must additionally assess compliance with the sector principles and conditions in Decree 52/2020/ND-CP — on permitted land types, area caps, financial capacity, support for people whose land is recovered, and environmental protection. Beyond approval, the project must complete land and construction procedures and EIA approval before implementation.
What conditions apply to a casino serving foreigners?
The casino must sit inside an integrated service, tourism and entertainment complex whose policy approval permits a casino, with minimum investment capital of USD 2 billion and minimum components such as a hotel, commercial areas and a convention centre, under Decree 03/2017/ND-CP. The enterprise may open a casino point only with a casino Business Eligibility Certificate, one condition being disbursement of at least 50% of registered capital. Foreign players need a valid passport, must be 21 or older and have civil act capacity.
What is the maximum land area for a golf project?
Under Article 7 of Decree 52/2020/ND-CP: a standard 18-hole golf course may not exceed 90 hectares (on average no more than 5 hectares per hole); a first-built golf project may not exceed 270 hectares, equivalent to at most 54 holes. Defence and security land, forest land, rice land (except the up-to-5-hectare single-crop exception in midland and mountainous areas), industrial park land and dike or coastal protection corridors may not be used for golf.
What tax incentives apply to a resort tourism project?
Incentives follow the general frame, with no casino-specific package: a tourism project in an incentivised sector or area enjoys preferential corporate income tax rates, tax exemption and reduction periods, and land-rent incentives under tax law and the incentive lists. Casino operations additionally bear special consumption tax under sector rules. Financial modelling should separate the resort complex (potentially incentivised) from the casino part (special consumption tax and separate control).
May Vietnamese nationals play at casinos in Vietnam?
Only under the pilot mechanism at casino points authorised by competent authority for the Vietnamese-player pilot (notably Phu Quoc and Van Don), under Decree 03/2017/ND-CP. Vietnamese players must be 21 or older, have full civil act capacity and prove regular income from VND 10 million per month with prescribed documents. Outside pilot points, Vietnamese casinos serve only foreigners and overseas Vietnamese holding foreign passports.
This article has been quality-reviewed by the FLAW AI Legal Council