In October 2025, a meeting at the Saigon Hi-Tech Park (SHTP) between Mr. Kenneth Tse, General Director of Intel Products Vietnam (IPV), and Mr. Nguyen Van Duoc, Chairman of the Ho Chi Minh City (HCMC) People’s Committee, marked a significant development for Vietnam’s high-tech ambitions. Intel announced it would relocate its assembly, testing, and packaging (ATP) operations from Costa Rica to Vietnam. This decision ultimately helps restore momentum after the corporation previously shifted a 3.3 billion USD semiconductor manufacturing project to Poland following concerns that the OECD’s Global Minimum Tax may reduce VN’s attraction. Similarly, AT&S, an Austrian high-tech electronics company, conducted investment surveys and expressed interest in investing in Vietnam but ultimately shifted to Malaysia, citing the lack of cost-based support mechanisms and readily available high-skilled technology labour.
According to the report on the draft Decree on the establishment, management, and utilization of the Investment Support Fund[1], the Ministry of Finance notes several shortcomings in the country’s investment incentive framework, including: (1) incentives remain insufficiently diversified, relying primarily on corporate income tax (CIT) exemptions and reductions, as well as land-rent incentives, while cost-based support mechanisms are largely absent; and (2) the policy framework has not kept pace with evolving international practices and the changing global context, particularly following the introduction of the Global Minimum Tax.
To address these constraints, in November 2025, the Ministry of Science and Technology issued Circular No. 33/2025/TT-BKHCN, which sets out eligibility criteria for CIT incentives applicable to enterprises implementing electronic equipment manufacturing projects. Under this framework, enterprises qualify for incentives if they utilize semiconductor chips in their projects and meet one of two conditions: (1) the chips are based on designs owned by Vietnamese organizations, enterprises, or individuals; or (2) the chips are manufactured, packaged, or tested (APT) in Vietnam.
With respect to incentives for scientific research, technological development, and innovation, enterprises must satisfy requirements related to dedicated human resources and R&D expenditure. Particularly, they are required to maintain a specialized R&D unit with at least 10 personnel holding university degrees or higher, of whom at least 50% must be Vietnamese nationals (for small and medium-sized enterprises, the minimum requirement is 3 personnel). R&D expenditure must account for at least 2% of average net revenue over three consecutive fiscal years or reach approximately 7.6 million USD per year or more during the same period. For enterprises operating for fewer than three years, expenditure is calculated on an average basis over the operating period, if it covers at least one full fiscal year.
* * * * *
References: 1. Cafe F, 15 December 2025
2. The Investor Vafie Magazine, 22 December 2025
3. Cafe F, 22 December 2025
[1] It has been officially adopted as of 31 December 2024.
