A battery plant’s package has three independent layers — land, CIT and non-tax support
An EV battery plant in Vietnam does not receive one single ‘incentive package’ but three layers from three different rule systems, each with its own conditions and clock. The land layer: exemption of land rent during basic construction and for a number of years after completion depending on location and project character under the land framework (Law on Land No. 31/2024/QH15 and guiding decrees on land rent) — projects in especially difficult areas or specially encouraged categories are exempted longer than projects in ordinary industrial parks. The CIT layer: anchored in the Law on Corporate Income Tax No. 67/2025/QH15 — Article 18 conditions, Article 19 entry into force (only three clauses), Article 20 transition — with the typical top-tier frame for a high-tech/large-scale project being a 10% preferential rate for 15 years, 4 years of exemption and a 50% reduction for the next 9 years. The non-tax layer: training support, connection infrastructure and one-stop procedures in the industrial park — real value, but not freely convertible into money.
The QDMTT layer for this very battery plant is analysed separately in FDI-LC-4018 in this batch; this article presents only the domestic package. Sector and location conditions tie to the Law on Investment No. 143/2025/QH15 (replacing Law No. 61/2020/QH14 from 1 March 2026).
Valuing the package: price each layer on one forecast — never add disconnected maxima
The question ‘what is the package worth in total’ can only be answered with a model: take the project’s own financial forecast (revenue, taxable income by year, contractual land rent, planned training spend), apply each layer in turn, and measure the difference against a no-incentive scenario. The CIT layer’s value is the tax saved across exemption and reduction years, loss carry-forwards considered; the land layer’s value is the rent exempted over the years, discounted if a single present figure is needed; training support counts only where a budget or programme is confirmed in writing. Adding each layer’s statutory maximum — the longest land exemption plus the richest tax frame — produces an advertising number, not a package value, because those maxima belong to different location conditions and never co-occur for one real project. This article deliberately gives no total for ‘a battery plant in general’, because no such general project exists.
One variable changes every calculation: if the group is in scope of the global minimum tax (consolidated revenue of EUR 750 million or more), the CIT layer’s value is cut by the QDMTT top-up under Resolution 107/2023/QH15 and Decree 236/2025/ND-CP — the package model must run both with-QDMTT and without-QDMTT scenarios (see FDI-LC-4018).
Keeping the whole package: each layer has its own failure point
Land rent exemption ties to the schedule of putting land into use and to the registered land purpose; prolonged delay or off-purpose use can claw the exemption back. CIT incentives tie to the incentivised sector character, separate accounting and capital schedule — the clawback mechanism for missed capital/revenue conditions is analysed in FDI-LC-4079. Training support ties to specific programmes and worker categories. Investors should govern the package as a portfolio of conditions with an annual review calendar, not treat the initial incentive document as lifetime insurance: in practice, projects lose incentives layer by layer at different inspections, and the layer clawed back first is usually the one with the most easily verified condition — the capital disbursement schedule.
Frequently Asked Questions
What incentives does an EV battery plant receive?
Three main layers: land rent exemption under the land framework (duration depends on location and project character, including the basic construction period and years after completion); CIT incentives under the Law on Corporate Income Tax No. 67/2025/QH15 (typical top-tier frame: 10% rate for 15 years, 4 years exempt, 50% reduction for the next 9); and non-tax support such as training and infrastructure. Each layer has its own conditions and clock.
Is land rent exempted?
Yes, it can be exempted: incentivised projects are exempt from land rent during basic construction and for additional years after completion depending on location — especially difficult areas earn the longest exemption, potentially the whole lease term for specially encouraged projects. The exact years must be confirmed against the land lease decision and the exemption frame at the project’s locality; there is no single figure for every battery plant.
How many years of preferential CIT?
Under the typical top-tier frame: a 10% preferential rate for 15 years, with 4 years of exemption from the first taxable-income year and a 50% reduction of tax payable for the following 9 years; afterwards the standard rate applies once the preferential-rate period also ends. The exact package depends on sector, location conditions and the project’s investment file under Article 18 of the Law on Corporate Income Tax No. 67/2025/QH15.
What is the total value of the incentive package?
There is no fixed total — and no figure offered without a model should be trusted. Total value must be computed on the project’s own forecast: tax saved across exemption/reduction years plus exempted land rent plus documented support, on one timeline. Adding statutory maxima of each layer is wrong because they belong to different location conditions. If the group is in QDMTT scope, the tax layer shrinks further (see FDI-LC-4018).
