Labour and Employment

Intra-corporate transferee (ICT): Vietnam’s work permit exemption for multinationals

Multinational corporate office towers at night

For multinational groups moving staff from a foreign parent or affiliate into Vietnam, the intra-corporate transferee (ICT) route is the most important work permit exemption, set out in Article 7.13(b) of Decree 219/2025/ND-CP (effective 07/08/2025, replacing Decrees 152/2020 and 70/2023).

Four cumulative conditions

1. Twelve consecutive months. The employee must have worked for the foreign enterprise for at least 12 consecutive months immediately before the transfer to Vietnam — evidenced by an employment certificate and the parent company’s assignment letter.

2. Commercial presence in Vietnam. The foreign enterprise must have established a commercial presence in Vietnam (subsidiary, branch, representative office, or another lawful form).

3. Within 11 WTO service sectors. The transfer must fall within the 11 service sectors of Vietnam’s WTO commitments (business, communications, construction, distribution, education, environmental, financial, health and social, tourism, recreational–cultural–sporting, transport).

4. The right position. The transferee must hold a manager, executive director, or expert title.

Procedure: apply for CONFIRMATION of exemption

ICT belongs to the confirmation track — the 3-working-day notification-only route does not apply. The employer files between 60 and 10 days before the intended start date; processing takes 5 working days; the confirmation is valid for up to 2 years and grounds an LD2 visa and temporary residence card.

The dossier includes the parent company’s assignment letter, proof of 12 consecutive months of employment, and evidence of commercial presence. Foreign-issued documents need consular legalization plus certified Vietnamese translation (or Apostille for Hague Convention members).

ICT vs the under-90-day route

The under-90-days-per-year route (Article 7.13(a)) needs only a 3-working-day notification — fast, but counted cumulatively across the calendar year, so it does not suit long postings or frequent travel. ICT has no day-count cap but demands all four conditions plus the confirmation procedure. Picking the wrong route means working without a legal basis.

Must ICT transferees prove 12 months of employment?

Yes — 12 consecutive months with the foreign enterprise immediately before transfer, proved by an employment certificate and assignment letter. Missing either the seniority or the commercial-presence condition disqualifies the ICT route.

Does ICT require the 15-day job posting?

No — intra-corporate transfer is exempt from the foreign-labor demand approval step (like service-contract assignments).

How long is the ICT exemption confirmation valid?

Up to 2 years; under Decree 219/2025 it may now be extended once for up to 2 more years, instead of requiring a fresh application as before.

What if the parent has no commercial presence in Vietnam yet?

The ICT route is unavailable. The worker must then obtain a regular work permit (expert, manager, or technical worker) with the full demand-approval and Article 18 dossier procedure.

Can an ICT transferee work in multiple provinces?

Yes — Decree 219/2025 provides that a foreign worker serving the same employer in multiple provinces need not update the permit/confirmation for each additional workplace.

For detailed advice on the ICT intra-corporate transfer route, contact FLAT Law Firm.


This article has been quality-reviewed by the FLAW AI Legal Council. Content was prepared by the FLAT Law Firm AI Legal Council and has not been reviewed by a human lawyer.