Intra-Corporate Transferee Under Decree 219/2025/ND-CP and Associated Risks

Intra-corporate transferee (ICT) is a mechanism for transferring foreign employees from a overseas parent company to a commercial presence in Vietnam, specifically regulated under Article 154.13.b of the 2019 Labor Code and detailed in Article 3.b of Decree 219/2025/ND-CP. To apply this mechanism legally, personnel must concurrently satisfy three mandatory conditions: holding an expert/managerial position, having a direct equity relationship between the two entities, and having a minimum of 12 consecutive months of prior employment with the parent company within the 11 service sectors committed under the WTO. The article below from Vina Boueki provides a comprehensive analysis of the latest legal framework, key differences compared to non-ICT transfers, along with wage reimbursement and corporate income tax (CIT) risks that HR and Finance departments need to optimize immediately.

1. Legal Definition of Intra-Corporate Transferee Under Decree 219/2025/ND-CP

The concept of intra-corporate transferee has been standardized to create a clear legal framework for multinational corporations when bringing senior personnel into Vietnam to work. According to Article 154.13.b of the 2019 Labor Code (cross-referenced in detail under Article 3.b of Decree 219/2025/ND-CP), this form is clearly defined as:

“Intra-corporate transferee: A foreign worker who is temporarily transferred within an overseas enterprise that has established a commercial presence in the territory of Vietnam within the scope of 11 service sectors in Vietnam’s Schedule of Specific Commitments in Services with the World Trade Organization (WTO), and who has been employed by the foreign enterprise for at least 12 consecutive months prior to the transfer.”

Thus, the core nature of an intra-corporate transferee is not the new recruitment of a foreign worker in Vietnam. It is a temporary secondment of personnel from an overseas parent company to a legally established business entity in Vietnam to perform specialized managerial, operational, or tech-transfer assignments.

2. Three Mandatory Conditions to Be Satisfied Concurrently for ICTs

For a foreign employee to be approved under the intra-corporate transferee category, Vietnamese law requires the enterprise to fully demonstrate all three prerequisite conditions below. Failing to meet even one of these three standards will immediately divert the application file toward local labor contract engagement or standard employee transfer.

No.	Legal Condition	Detailed Content Under Regulations	Supporting Documentation Mapping
1	Suitable Job Position	The foreign employee must hold one of the following positions: Manager, Executive Director, Expert, or Technical Worker.	Appointment letter, parent company organizational chart, proof of experience.
2	Direct Equity Relationship	The transferring foreign parent company must have established a commercial presence in Vietnam in the form of a foreign-invested economic organization, representative office/branch, or an executive office under a Business Cooperation Contract (BCC).	Investment Registration Certificate (IRC), Enterprise Registration Certificate (ERC), Branch License.
3	Minimum Seniority	Employed and continuously working for at least 12 months at the foreign parent company immediately prior to the transfer date to Vietnam.	Employment contract with the parent company, proof of 12 months of foreign social insurance/tax contributions.

Important note from Vina Boueki: Regulations on intra-corporate transferees strictly apply within the 11 service sectors under Vietnam’s WTO Schedule of Commitments. These sectors include: Business Services, Communication Services, Construction and Related Engineering Services, Distribution Services, Educational Services, Environmental Services, Financial Services, Health Related and Social Services, Tourism and Travel Related Services, Recreational, Cultural and Sporting Services, and Transport Services. Any enterprise operating outside the scope of these 11 service sectors will not qualify for this mechanism.

3. Key Differences Between Intra-Corporate Transferee and Overseas Assignment

In actual FDI human resource operations, many enterprises confuse two mechanisms: “Intra-corporate transferee” (regulated under Point b, Article 3) and “Transferred from an overseas agency, organization, or enterprise to work in Vietnam” (regulated under Point h, Article 3) of Decree 219/2025/ND-CP. This confusion leads to incorrect dossier preparation and faces the risk of work permit rejection.

3.1 Difference in the Transferring Entity

Under the ICT mechanism, the transferring entity must be the foreign parent company itself—the entity that holds the direct investment or directly established the commercial presence in Vietnam.

In contrast, standard transfer from an overseas organization applies when personnel are transferred from a affiliate/subsidiary company within the same corporate group that is not the direct investor establishing the commercial presence in Vietnam, or when transferred to a branch not directly owned by the transferring entity.

3.2 Difference in the 12-Month Seniority Requirement

The ICT mechanism strictly mandates that the employee must have worked continuously for 12 months or more at the parent company prior to being transferred to Vietnam.

For standard transfers from overseas organizations, current regulations do not mandate this 12-month continuous tenure criterion. This provides businesses with greater flexibility when needing to assign newly recruited overseas staff to Vietnam right away.

3.3 Difference in Registered Business Scope

Intra-corporate transfer is strictly limited to the scope of 11 service sectors committed under the WTO.

On the other hand, standard transfers from overseas organizations are not bound by the list of 11 WTO service sectors, allowing application across manufacturing, processing, agriculture, and other business industries.

4. Practical Features and Key Legal & Financial Risks

The core legal nature of an intra-corporate transferee is that the worker retains their employment relationship and remains under the management of the overseas parent company, rather than signing a labor contract with the entity in Vietnam. This specific detail determines the entire accounting approach for salary, insurance, and taxation.

4.1 Regulations on Social Insurance and Employment Contracts

Because no employment relationship is formed under a local labor contract with the entity in Vietnam, personnel under the ICT category have the following legal characteristics:

• Social Insurance (SI) / Health Insurance (HI): Foreign workers under the ICT category are exempt from mandatory Social Insurance and Health Insurance contributions in Vietnam.

• Employment Contract: The enterprise in Vietnam is not permitted to sign a local employment contract with these personnel. The working relationship in Vietnam is governed by the Internal Transfer Decision issued by the parent company.

4.2 Risk Warning on Salary Payment and CIT Deductibility

This represents the single biggest risk area encountered by many FDI enterprises during labor inspections and tax audits. All salaries, bonuses, and benefits of ICT personnel must be paid directly by the overseas parent company.

Practical Risk: If the entity in Vietnam executes the work permit application under the ICT mechanism but actually pays the salary directly and books local payroll expenses in Vietnam, it will incur severe consequences:

• Labor Perspective: The Work Permit may be declared invalid by regulatory authorities under Article 156.4 of the 2019 Labor Code due to misrepresenting the working arrangement. The enterprise may face administrative fines ranging from VND 10,000,000 to VND 20,000,000 under Article 32.2 of Decree 12/2022/ND-CP.

• CIT Perspective: Tax authorities will disallow all booked salary and bonus expenses from deductible expenses for CIT calculation, resulting in major tax back-assessments and heavy late-payment interest penalties.

To ensure strict compliance and optimize operations, enterprises can refer to Vina Boueki’s Work Permit Advisory Service to receive tailored, risk-free foreign workforce structures from our expert team.

5. Optimal Workforce Management Strategy for FDI Enterprises

To completely resolve legal compliance challenges and optimize costs for foreign personnel, Vina Boueki recommends a standardized action plan for HR and Accounting departments:

1. Review Registered Business Scope: Cross-check the Vietnam entity’s Investment Registration Certificate against the 11 WTO service sectors to accurately confirm eligibility for the ICT mechanism.

2. Audit Seniority Records: Review employment contracts, payroll records, and tax/insurance contribution proof at the parent company to ensure fulfillment of the 12-consecutive-month requirement prior to transfer.

3. Standardize Payroll Flow: Establish a clear salary payment agreement directly from the overseas parent company. If the Vietnam entity intends to pay salaries directly to the employee, switch the Work Permit mechanism to the local employment contract category.

With many years years of experience in FDI investment consulting, labor law, and operational HR management in Vietnam, Vina Boueki is always ready to partner with your enterprise in building a solid compliance model, eliminating legal risks, and optimizing operational costs.

6 Core Changes in Work Permit Application Procedures for Foreigners Under Decree 219/2025/ND-CP

Applying the new 2-step consolidated process under Decree 219/2025/ND-CP to apply for work permits for foreign nationals in Vietnam. This updated legal framework eliminates the separate labor demand approval document, cuts processing time to 10 working days, and tightens regulations on intra-corporate transferees. The legal framework governing the employment of foreign workers in Vietnam recently underwent comprehensive reform with the enactment of Decree 219/2025/ND-CP, effective August 7, 2025, which officially replaces Decree 152/2020/ND-CP and Decree 70/2023/ND-CP. Subsequently, Resolution 24/2026/NQ-CP—effective from April 29, 2026, to February 28, 2027—further streamlines administrative requirements and removes redundant paperwork.

This article synthesizes all core updates, including: shortening the process from 3 steps to 2 steps, eliminating periodic labor utilization reporting, tightening regulations on intra-corporate transfers, establishing an exemption notification mechanism, enabling electronic authentication, and extracting shared database records. At the same time, Vina Boueki provides a detailed analysis of practical risks regarding corporate income tax (CIT), social insurance, and entry visas to help businesses proactively review their compliance.

1. Current Legal Framework Governing Foreign Labor in Vietnam

The issuance of Work Permits to foreign nationals is currently subject to direct regulation under systematic government-level legal documents. The Government issued Decree 219/2025/ND-CP, effective August 7, 2025, laying the foundation for a comprehensive reform in managing foreign workers. This document completely repeals the previous Decree 152/2020/ND-CP and Decree 70/2023/ND-CP, re-establishing standards regarding conditions, procedures, and employment forms for international personnel. On April 29, 2026, Resolution 24/2026/NQ-CP officially took effect (valid through February 28, 2027) to continuously drive the reduction and simplification of administrative procedures across various sectors, including the issuance and extension of Work Permits. Businesses managing foreign staff must update both documents concurrently to ensure full legal compliance across all HR dossiers.

2. 6 Core Changes When Applying for Work Permits for Foreigners

Decree 219/2025/ND-CP and Resolution 24/2026/NQ-CP introduce 6 critical shifts in practical management.

① Streamlining the Procedure from 3 Steps Down to 2 Steps for Foreigners

Under former regulations in Decree 152/2020/ND-CP, businesses had to complete 3 separate procedures sequentially: recruitment advertising for Vietnamese workers, applying for an approval document on the demand to use foreign workers, and submitting the application for Work Permit issuance. Under new regulations, the separate procedure for “Approval of demand to use foreign labor” has been eliminated. The current processing routine is consolidated into 2 steps:

Recruitment advertising for Vietnamese workers: Applies only to cases under Employment Contracts, carried out publicly at least 5 days prior to executing the next step. Submitting consolidated dossiers: Businesses submit the “Explanatory report on the demand for foreign labor and application for Work Permit issuance” at the same time. Submission must be done within 60 days and at least 10 days before the expected start date of employment. The processing time for new Work Permit applications is fixed at 10 working days from the date the competent authority receives complete and valid dossiers under Article 22 of Decree 219/2025/ND-CP. Work Permit Application Flowchart Comparison:

Old process (Decree 152/2020/ND-CP): Recruitment advertising for Vietnamese workers -> Requesting Labor Demand Approval -> Applying for Work Permit issuance. New process (Decree 219/2025/ND-CP): Recruitment advertising for Vietnamese workers (applies to Employment Contracts only) -> Submitting Consolidated Explanatory Report and Application for Work Permit issuance (Processing time: 10 working days).

② Eliminating Periodic Foreign Labor Utilization Reporting

Enterprises are officially no longer required to prepare and submit semi-annual or annual reports on foreign labor utilization to the Department of Labor, Invalids and Social Affairs (DOLISA). Supervision has shifted to post-clearance inspection via interconnected electronic databases. However, the obligation to submit periodic reports on Vietnamese labor utilization remains in force.

③ Mandatory Selection of a Single Form of Employment

Under Article 2 of Decree 219/2025/ND-CP, regulatory authorities require foreign employees to select only 01 form of employment in Vietnam. This creates a major risk point for personnel under Intra-Corporate Transfers (ICT). If an employee enters Vietnam under ICT status but the entity in Vietnam simultaneously pays payroll or enters into an Employment Contract, the company faces arising legal risks:

The Work Permit risks being declared invalid pursuant to Clause 4, Article 156 of the 2019 Labor Code. Administrative fines ranging from VND 10,000,000 to VND 20,000,000 under Clause 2, Article 32 of Decree 12/2022/ND-CP. All salary expenses paid under the wrong arrangement risk being disallowed as deductible expenses by tax authorities when calculating CIT. In cases where a switch from ICT to an Employment Contract is required, the enterprise incurs obligations for mandatory social and health insurance, amounting to approximately 30% of the salary fund.

④ Simplifying Procedures for Work Permit Exemptions

Certain foreign workers eligible for Work Permit exemptions (e.g., individuals married to Vietnamese citizens under Clause 4, Article 9 of Decree 219/2025/ND-CP) no longer need to apply for a “Certificate of Work Permit Exemption.” Instead, when handling work permit procedures for foreign nationals, the enterprise or employee only needs to submit a written notification to the competent authority at least 03 working days before the expected start date.

⑤ Applying Electronic Authentication and Parallel Criminal Record Certificate Requests

Enterprises are permitted to authorize online applications for Criminal Record Certificates via the National Public Service Portal simultaneously with the preparation of Work Permit dossiers. Electronic criminal record results are shared directly between governing bodies, minimizing waiting times. In addition, using certified electronic copies (for passports, Criminal Record Certificates, health checkups, and Enterprise Registration Certificates – ERC) processed at Commune/Ward People’s Committees yields results within 01 working day, completely replacing the requirement for physical notarized hard copies.

⑥ Reducing Application Components Under Resolution 24/2026/NQ-CP

Resolution 24/2026/NQ-CP brings an important update: when foreign workers’ information is already available on the shared National Database System (such as valid passport copies, portrait photos, or unchanged previous Work Permit details), enterprises are exempt from resubmitting these documents. This applies consistently to both new issuances and extensions of Work Permits under Articles 7, 18, and 27 of Decree 219/2025/ND-CP.

3. Summary Table of Work Permit Changes

Comparison Criteria	Old Regulations (Decree 152/2020/ND-CP)	New Regulations (Decree 219/2025/ND-CP & Res 24/2026/NQ-CP)
Application Process	3 separate steps (Recruitment -> Labor Demand Approval -> Work Permit Application)	2 consolidated steps (Recruitment -> Submitting Consolidated Explanatory Report & Work Permit Application)
Processing Time	Multi-stage processing, taking 20 to 30 working days	10 working days upon receipt of a complete and valid application
Periodic Foreign Worker Reporting	Semi-annual and annual reporting required	Completely abolished; shifted to electronic database monitoring
Intra-Corporate Transfers (ICT)	Payroll mechanisms in Vietnam were not strictly enforced	Mandatory selection of 01 working form; ICT personnel cannot receive local payroll/sign local employment contracts
Work Permit Exemption Confirmation	Mandatory submission of application for Exemption Certificate	Shifted to submitting a Notification (at least 3 working days prior) for eligible categories
Physical Paperwork Components	Notarized copies required for all documents	Shared electronic database records utilized; resubmission of existing system documents exempted

4. Practical Risks and Compliance Recommendations for Enterprises

In accompanying international corporations and FDI enterprises, Vina Boueki has observed that many organizations frequently encounter issues in legal-technical details. Below is a detailed breakdown alongside actionable solutions:

4.1. “Manager” vs. “Executive Director” Titles

Proof documents for these two titles differ significantly. The Executive Director position strictly requires a Work Experience Certificate showing 3 years in an equivalent position, along with a lengthy Consular Legalization process (which typically takes around 90 days). If the foreign worker cannot prepare the Experience Certificate in time, the enterprise should consider registering the title under “Manager” accompanied by an Appendix amending the Company Charter or a corresponding Appointment Decision.

4.2. Converting Entry Visas to Temporary Residence Cards (TRC)

Workers entering on tourist visas or under a 45-day visa exemption cannot convert directly to a Labor Visa (LD1, LD2) or Temporary Residence Card (TRC) inside Vietnam. To resolve this, the worker must depart Vietnam and re-enter using an Electronic Visa (E-visa) registered under the proper business/employment purpose after the Work Permit has been granted.

4.3. Reviewing Payroll Arrangements for Intra-Corporate Transferees

FDI enterprises should review their entire roster of foreign staff under intra-corporate transfers. If payroll payments originate from the company’s local bank account in Vietnam for ICT personnel, the business must adjust its contract structures to prevent the Work Permit from being declared invalid and to avoid CIT back-taxes.

4.4. Key Considerations When Switching Between Employment Contracts and Intra-Corporate Transfers

Switching from a local Employment Contract to an Intra-Corporate Transfer often meets significant obstacles during authority reviews. Therefore, businesses need to carefully plan their labor structures right from the initial application phase. To explore detailed solutions for comprehensive HR management and legal investment advisory, enterprises can refer to Vina Boueki’s legal and operational services for expert guidance.

Conclusion

Decree 219/2025/ND-CP and Resolution 24/2026/NQ-CP have introduced a transparent mechanism that cuts down administrative processing time while enforcing strict compliance regarding employment arrangements and tax obligations. Understanding these core changes helps enterprises optimize operational costs and eliminate arising legal risks.

Is your business facing obstacles in Work Permit application procedures for foreign workers, preparing consolidated Explanatory Reports, organizing electronic authentication files, or seeking a complete audit of your foreign labor documentation system? Contact Vina Boueki’s team of experienced advisors today for optimal compliance solutions.

Vina Boueki brings extensive expert experience in investment legal consulting, work permits, payroll/C&B services, personal income tax, corporate income tax, and social insurance for international enterprises (especially Japanese, Korean, and FDI corporations) in Vietnam. Vina Boueki is committed to delivering service quality according to rigorous Japanese standards—operating with flexibility and a deep understanding of practical Vietnamese law under our core principle: “Accurate – Confidential – Dedicated – Responsible.”

In 2025, PIT finalization for expatriates demands absolute precision in determining residency status and declaring global income. To ensure legal compliance and avoid administrative penalties, businesses must master the deadlines, dependent documentation requirements, and the latest regulations on electronic transactions.

1. Expatriates Subject to PIT Finalization

Correctly identifying the subject is the prerequisite step to applying the appropriate tax rate. Under current regulations, foreigners working in Vietnam are divided into two main groups based on their duration of stay and residence.

Resident Individuals

An individual is identified as a resident of Vietnam if they satisfy one of the following conditions:

• Being present in Vietnam for 183 days or more within a calendar year or within 12 consecutive months from the first day of arrival in Vietnam.

• Having a regular residence in Vietnam according to the law on residence or having a leased house for stay in Vietnam with lease contracts of 183 days or more within the tax year.

For resident individuals, taxable income is income arising within and outside the territory of Vietnam, regardless of where the income is paid.

Non-resident Individuals

Individuals who do not meet the above conditions are considered non-residents. This group is only liable for PIT on the portion of income arising in Vietnam at a flat tax rate of 20%, with no family relief deductions allowed.

Authorized Finalization Cases

A business may perform the finalization on behalf of an employee if that individual only has income from wages or salaries, has signed a labor contract of 3 months or more with the business, and is actually working there at the time of finalization.

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2. Standard PIT Finalization Process for Foreign Experts

To ensure accuracy and optimize time, businesses should apply a streamlined yet comprehensive control process as follows:

1. Review and Collect Documents: Gather all tax withholding certificates, Letters of Confirmation for income paid abroad, and invoices/documents related to insurance or charities.

2. Determine Deductions: Check family relief records for the individual and their dependents. Note that dependent documents from abroad must be consularly legalized in accordance with regulations.

3. Prepare and Submit Declarations: Use the latest HTKK software or declare online via the General Department of Taxation’s e-portal. Ensure that taxable income and withheld tax figures match the accounting books.

4. Tax Payment or Refund: After submission, the business or individual pays any additional tax (if underpaid) or proceeds with tax refund/offset procedures for the next period (if overpaid).

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3. Updates on the Latest 2025 Legal Regulations and Decrees

The year 2025 marks a turning point in the digitalization of tax management. Decree 126/2020/NĐ-CP and Law on Tax Administration No. 38 remain the primary legal frameworks, but new guiding circulars have emphasized the following:

• Personal Digital Signatures: Individuals performing self-finalization are encouraged and gradually required to have a digital signature or register an e-tax transaction account to approve documents online.

• Submission Deadlines: For individuals performing self-finalization, the deadline is the last day of the 4th month from the end of the calendar year. For businesses finalizing on behalf of employees, the deadline is the last day of the 3rd month.

• Global Income Processing: Tax authorities are increasing the review of international tax information exchange data to monitor income earned outside of Vietnam by foreign experts.

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4. Calculating PIT for Expatriates with Global Income

This is the most complex aspect of tax finalization. For resident individuals, income from all sources worldwide must be converted into Vietnam Dong (VND) using the average interbank foreign exchange market rate at the time the income arises.

Applying Double Taxation Agreements (DTA)

Vietnam has signed DTAs with over 80 countries and territories. If a foreigner has paid income tax in their home country (e.g., Japan), they may deduct the tax paid abroad from the tax payable in Vietnam, provided it does not exceed the tax payable calculated under Vietnam’s tax tariff.

Utilizing DTAs effectively not only ensures compliance with international law but also helps businesses significantly optimize senior personnel costs.

Monthly Taxable Income (Million VND)	Tax Rate
Up to 5	5%
Above 5 to 10	10%
Above 10 to 18	15%
Above 18 to 32	20%
Above 32 to 52	25%
Above 52 to 80	30%
Above 80	35%

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5. Required Documents for Expatriate PIT Finalization

A well-prepared dossier will help businesses shorten the processing time with tax authorities. Essential documents include:

• Tax finalization return Form No. 02/QTT-TNCN (for individuals) or 05/QTT-TNCN (for organizations).

• Appendix listing details of dependents for family relief.

• Certified copy of passport to verify the number of days stayed in Vietnam.

• Tax withholding certificates and global income confirmation from the parent company or paying entity abroad.

• Dependent supporting documents (if any): Birth certificates, marriage certificates—consularly legalized and notarized with translation.

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6. PIT Refund for Foreigners upon Completion of Assignment in Vietnam

When foreign experts finish their term and leave Vietnam, they must perform tax finalization up to the date of departure. This is a crucial step to close the tax identification number (TIN) and complete obligations to the Vietnamese state.

In many cases, the monthly withheld tax is higher than the actual tax payable based on the actual working time. In such instances, the individual is entitled to a tax refund. Vina Boueki recommends that businesses support experts in completing this procedure before they leave the territory to ensure their rights and avoid future legal complications should they wish to return to work.

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7. Common Mistakes and Legal Risks for Businesses

Below are the errors Vina Boueki frequently records during consulting:

• Incorrect Determination of Residency Status: Calculating a flat 20% tax for the entire year when the individual was actually in Vietnam for over 183 days.

• Omission of Income: Failing to declare cash allowances or non-monetary benefits (such as tuition for children or home leave airfare) which are taxable.

• Invalid Deduction Documents: Using overseas documents without the mandatory consular legalization stamp from the Vietnamese consulate.

• Late Submission: Leading to high administrative tax penalties as stipulated in Decree 125/2020/NĐ-CP.

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8. Professional PIT Finalization Services at Vina Boueki

With 20 years of experience accompanying FDI enterprises, particularly companies from Japan and South Korea, Vina Boueki is proud to provide comprehensive business support and tax finalization solutions. We understand that every figure on a declaration represents not just a financial obligation but the reputation of the business.

At Vina Boueki, our quality control process is built on Japanese standards: accurate, transparent, and confidential. Our team of experts does more than just calculate; we act as advisors, helping businesses review their entire salary, insurance, and HR policy systems to ensure maximum optimization.

During any tax audit or inspection, Vina Boueki is always ready to represent or accompany the business to explain and protect the unit’s legitimate interests based on a deep understanding of local laws.

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9. Frequently Asked Questions about PIT

Can an expat with two sources of income authorize a business to finalize their tax?

No. According to regulations, individuals with income from two or more sources must perform the finalization directly with the tax authorities.

How long does a PIT refund usually take?

By law, the processing time for a tax refund dossier is between 6 to 40 working days from the receipt of a complete and valid dossier, depending on whether it falls under the “Refund first, Audit later” or “Audit first, Refund later” category.

Does Vina Boueki support finalization for foreigners who have already returned home?

Yes. Vina Boueki provides authorization services to perform tax procedures for experts who have departed, ensuring all obligations are fully completed.

Conclusion

Performing PIT finalization for expatriates in 2025 requires meticulousness, legal expertise, and timely updates. A well-organized system will give businesses peace of mind to grow sustainably in the Vietnamese market. If your business is facing difficulties with documentation or wishes to optimize tax management processes, please contact the experts at Vina Boueki for the most dedicated and professional support.

Top 5 Reputable Work Permit Services for International Companies in Vietnam 2025

As the flow of foreign direct investment (FDI) into Vietnam grows stronger, so does the need for experts and senior personnel from around the world to directly manage and operate businesses. However, the process of obtaining a Work Permit (WP) for foreigners in Vietnam is complex, requiring a deep understanding of a legal landscape that is subject to frequent changes—especially with new regulations set to take effect from July 1, 2025. A minor oversight in this process can lead to delays in personnel planning, directly impacting business operations.

Choosing a consulting partner is not just about handling administrative procedures; it is a strategic decision to ensure smooth operations and legal compliance. This article will analyze the most critical criteria for selecting a service provider and introduce a list of the top 5 reputable firms trusted by international businesses for work permit consulting in Vietnam.

Why Choosing the Right WP Service Partner is a Strategic Decision

For international companies, which demand high standards of precision, transparency, and efficiency, selecting a work permit service partner is more than just outsourcing an administrative task. It is about finding an extension of their HR and legal departments—a partner who understands both the multinational corporate culture and Vietnam’s unique legal environment.

A poor choice can lead to unnecessary risks:

• Legal Risks: Applications being repeatedly rejected, experts unable to start work on schedule, and even potential administrative penalties for employing unlicensed labor.
• Increased Costs and Time: Protracted processes generate hidden costs, wasting the resources of the HR department and management.
• Impact on Business Operations: Plans for project implementation, technology transfer, or factory operations can be stalled because key personnel are not yet cleared to work.

Therefore, an ideal partner is one who not only executes procedures but also provides strategic advice, foresees risks, and offers the most optimal solution for each company’s specific circumstances.

A List of the Top 5 Work Permit Consulting Firms for International Businesses

Here is a list of five providers highly regarded for their capabilities, experience, and understanding of the diverse needs of international companies in Vietnam.

1. Vina Boueki: A Comprehensive Partnership with International Standards

Topping the list is Vina Boueki, a firm that positions itself not just as a service provider but as a strategic partner throughout a company’s entire operational journey in Vietnam. With over 20 years of experience from its founding team in the legal and investment sectors, Vina Boueki offers a distinct solution that combines international quality standards with deep practical understanding of Vietnam.

• Key Strengths:
  • Integrated Service Ecosystem: Vina Boueki understands that a Work Permit is just one link in the operational chain. Therefore, it provides a complete solution package covering Company Establishment, sub-licenses, Visas, Temporary Residence Cards (TRCs), to Payroll Services, Tax, and Social Insurance (SI). This allows international businesses to work with a single point of contact, ensuring consistency and minimizing the administrative burden.
  • International Quality Standards & Vietnamese Know-How: Every process at Vina Boueki is built on rigorous international standards: precision, transparency, timely reporting, and meticulous attention to detail. Notably, our extensive experience serving numerous Japanese enterprises—globally recognized for their strict and demanding quality standards—has honed our service process to a level of outstanding precision and dedication. This proves our capability to meet and exceed the expectations of any international investor.
  • Capacity to Handle Complex Cases: With extensive hands-on experience, Vina Boueki has successfully managed numerous difficult cases for clients from many different countries, such as experts lacking specific required qualifications, unique job positions not listed in standard categories, or applications requiring urgent processing.
  • Multilingual Expert Team: Vina Boueki’s specialists can discuss and provide in-depth consultation directly in English, Japanese, and Vietnamese, breaking down language barriers and ensuring complex legal information is conveyed with the utmost accuracy.
• Best suited for: International companies of all sizes (from SMEs to large corporations) seeking a long-term strategic partner who not only solves immediate problems but also advises on a path of sustainable, compliant growth in Vietnam.

2. KPMG Legal

KPMG is one of the “Big Four” major names in the audit and advisory industry. Its legal arm in Vietnam offers a wide range of legal consulting services, including support for foreign employees.

• Key Strengths:
  • Global Brand: Its global reputation and network are a significant advantage, providing assurance to large multinational corporations.
  • Large Team of Lawyers: Capable of handling large-scale, complex legal matters.
• Points to Consider: Service fees are typically in the high range, and processes can be quite rigid, sometimes lacking the flexibility needed by SMEs or for requests that require a quick turnaround.

3. Acclime Vietnam

Acclime is a leading corporate service provider with an extensive network across Asia. In Vietnam, Acclime supports foreign investors in numerous areas, from company incorporation and accounting to tax and HR.

• Key Strengths:
  • Regional Network: Experience and presence in multiple Asian markets can be beneficial for companies with a regional expansion strategy.
  • Comprehensive Corporate Services: Offers a wide range of essential services for compliance and operations.
• Points to Consider: As a large, process-driven firm, the service may lack the deep personalization and flexibility of a boutique firm, especially when handling complex, non-standard labor cases.

4. Mazars Vietnam

Mazars is an international, integrated partnership specializing in audit, accountancy, advisory, tax, and legal services. With a strong presence in Vietnam, Mazars serves a wide range of foreign-invested enterprises.

• Key Strengths:
  • International Network: As a global brand, Mazars offers reliability through its international standards and processes.
  • Deep Expertise in Tax & Finance: This is Mazars’ core strength, making it a great fit for companies that prioritize financial and tax compliance.
• Points to Consider: Similar to other large advisory firms, the service can be less flexible and personalized. Work permit advisory is often bundled with larger financial packages and may not be the optimal choice for businesses with standalone needs.

5. Phuoc & Partners

Phuoc & Partners is a reputable Vietnamese law firm with extensive experience in corporate, labor, and tax law advisory for both local and international clients.

• Key Strengths:
  • Solid Legal Expertise: The team of lawyers has a deep understanding of the Vietnamese legal system.
  • Diverse Consulting Experience: Has worked with a wide variety of businesses, providing a practical perspective.
• Points to Consider: While professional, its primary focus on a purely legal perspective may not fully encompass the broader operational HR and payroll aspects that international businesses require.

At-a-Glance Comparison for an Easy Choice

For a clear overview, the table below compares the providers based on the criteria most important to an international enterprise.

Conclusion: Choosing a Partner, Not Just a Provider

Successfully obtaining a work permit for a foreign expert is more than just completing a set of documents. It is a critical first step in ensuring that high-quality human resources can contribute to your company’s success in Vietnam legally and sustainably. Choosing the right service provider is an investment in peace of mind, efficiency, and compliance.

Instead of facing complex procedures and potential risks on your own, let a partner who truly understands your needs walk alongside you. A partner who not only executes but advises; who not only follows instructions but acts in the long-term interest of your business.

Are you facing challenges with HR procedures for foreign experts or in need of a reliable partner for compliant operations in Vietnam? Connect with Vina Boueki’s expert team today for a complimentary strategic consultation. We are committed to delivering solutions, not just services.

To learn more about the latest regulations, companies can refer to the official portal of the Ministry of Labour, Invalids and Social Affairs (MOLISA).

Top 5 Reputable Work Permit Services for International Companies in Vietnam 2025

As the flow of foreign direct investment (FDI) into Vietnam grows stronger, so does the need for experts and senior personnel from around the world to directly manage and operate businesses. However, the process of obtaining a Work Permit (WP) for foreigners in Vietnam is complex, requiring a deep understanding of a legal landscape that is subject to frequent changes—especially with new regulations set to take effect from July 1, 2025. A minor oversight in this process can lead to delays in personnel planning, directly impacting business operations.

Choosing a consulting partner is not just about handling administrative procedures; it is a strategic decision to ensure smooth operations and legal compliance. This article will analyze the most critical criteria for selecting a service provider and introduce a list of the top 5 reputable firms trusted by international businesses for work permit consulting in Vietnam.

Why Choosing the Right WP Service Partner is a Strategic Decision

For international companies, which demand high standards of precision, transparency, and efficiency, selecting a work permit service partner is more than just outsourcing an administrative task. It is about finding an extension of their HR and legal departments—a partner who understands both the multinational corporate culture and Vietnam’s unique legal environment.

A poor choice can lead to unnecessary risks:

• Legal Risks: Applications being repeatedly rejected, experts unable to start work on schedule, and even potential administrative penalties for employing unlicensed labor.
• Increased Costs and Time: Protracted processes generate hidden costs, wasting the resources of the HR department and management.
• Impact on Business Operations: Plans for project implementation, technology transfer, or factory operations can be stalled because key personnel are not yet cleared to work.

Therefore, an ideal partner is one who not only executes procedures but also provides strategic advice, foresees risks, and offers the most optimal solution for each company’s specific circumstances.

A List of the Top 5 Work Permit Consulting Firms for International Businesses

Here is a list of five providers highly regarded for their capabilities, experience, and understanding of the diverse needs of international companies in Vietnam.

1. Vina Boueki: A Comprehensive Partnership with International Standards

Topping the list is Vina Boueki, a firm that positions itself not just as a service provider but as a strategic partner throughout a company’s entire operational journey in Vietnam. With over 20 years of experience from its founding team in the legal and investment sectors, Vina Boueki offers a distinct solution that combines international quality standards with deep practical understanding of Vietnam.

• Key Strengths:
  • Integrated Service Ecosystem: Vina Boueki understands that a Work Permit is just one link in the operational chain. Therefore, it provides a complete solution package covering Company Establishment, sub-licenses, Visas, Temporary Residence Cards (TRCs), to Payroll Services, Tax, and Social Insurance (SI). This allows international businesses to work with a single point of contact, ensuring consistency and minimizing the administrative burden.
  • International Quality Standards & Vietnamese Know-How: Every process at Vina Boueki is built on rigorous international standards: precision, transparency, timely reporting, and meticulous attention to detail. Notably, our extensive experience serving numerous Japanese enterprises—globally recognized for their strict and demanding quality standards—has honed our service process to a level of outstanding precision and dedication. This proves our capability to meet and exceed the expectations of any international investor.
  • Capacity to Handle Complex Cases: With extensive hands-on experience, Vina Boueki has successfully managed numerous difficult cases for clients from many different countries, such as experts lacking specific required qualifications, unique job positions not listed in standard categories, or applications requiring urgent processing.
  • Multilingual Expert Team: Vina Boueki’s specialists can discuss and provide in-depth consultation directly in English, Japanese, and Vietnamese, breaking down language barriers and ensuring complex legal information is conveyed with the utmost accuracy.
• Best suited for: International companies of all sizes (from SMEs to large corporations) seeking a long-term strategic partner who not only solves immediate problems but also advises on a path of sustainable, compliant growth in Vietnam.

2. KPMG Legal

KPMG is one of the “Big Four” major names in the audit and advisory industry. Its legal arm in Vietnam offers a wide range of legal consulting services, including support for foreign employees.

• Key Strengths:
  • Global Brand: Its global reputation and network are a significant advantage, providing assurance to large multinational corporations.
  • Large Team of Lawyers: Capable of handling large-scale, complex legal matters.
• Points to Consider: Service fees are typically in the high range, and processes can be quite rigid, sometimes lacking the flexibility needed by SMEs or for requests that require a quick turnaround.

3. Acclime Vietnam

Acclime is a leading corporate service provider with an extensive network across Asia. In Vietnam, Acclime supports foreign investors in numerous areas, from company incorporation and accounting to tax and HR.

• Key Strengths:
  • Regional Network: Experience and presence in multiple Asian markets can be beneficial for companies with a regional expansion strategy.
  • Comprehensive Corporate Services: Offers a wide range of essential services for compliance and operations.
• Points to Consider: As a large, process-driven firm, the service may lack the deep personalization and flexibility of a boutique firm, especially when handling complex, non-standard labor cases.

4. Mazars Vietnam

Mazars is an international, integrated partnership specializing in audit, accountancy, advisory, tax, and legal services. With a strong presence in Vietnam, Mazars serves a wide range of foreign-invested enterprises.

• Key Strengths:
  • International Network: As a global brand, Mazars offers reliability through its international standards and processes.
  • Deep Expertise in Tax & Finance: This is Mazars’ core strength, making it a great fit for companies that prioritize financial and tax compliance.
• Points to Consider: Similar to other large advisory firms, the service can be less flexible and personalized. Work permit advisory is often bundled with larger financial packages and may not be the optimal choice for businesses with standalone needs.

5. Phuoc & Partners

Phuoc & Partners is a reputable Vietnamese law firm with extensive experience in corporate, labor, and tax law advisory for both local and international clients.

• Key Strengths:
  • Solid Legal Expertise: The team of lawyers has a deep understanding of the Vietnamese legal system.
  • Diverse Consulting Experience: Has worked with a wide variety of businesses, providing a practical perspective.
• Points to Consider: While professional, its primary focus on a purely legal perspective may not fully encompass the broader operational HR and payroll aspects that international businesses require.

At-a-Glance Comparison for an Easy Choice

For a clear overview, the table below compares the providers based on the criteria most important to an international enterprise.

Conclusion: Choosing a Partner, Not Just a Provider

Successfully obtaining a work permit for a foreign expert is more than just completing a set of documents. It is a critical first step in ensuring that high-quality human resources can contribute to your company’s success in Vietnam legally and sustainably. Choosing the right service provider is an investment in peace of mind, efficiency, and compliance.

Instead of facing complex procedures and potential risks on your own, let a partner who truly understands your needs walk alongside you. A partner who not only executes but advises; who not only follows instructions but acts in the long-term interest of your business.

Are you facing challenges with HR procedures for foreign experts or in need of a reliable partner for compliant operations in Vietnam? Connect with Vina Boueki’s expert team today for a complimentary strategic consultation. We are committed to delivering solutions, not just services.

To learn more about the latest regulations, companies can refer to the official portal of the Ministry of Labour, Invalids and Social Affairs (MOLISA).

KEY CHANGES TO WORK PERMIT REGULATIONS FOR FOREIGNERS IN VIETNAM, EFFECTIVE AUGUST 2025

August 7, 2025, has become a landmark date for every enterprise employing foreign labor in Vietnam. With the issuance of Decree No. 219/2025/ND-CP (hereinafter referred to as “Decree 219”) by the Government, a comprehensive and unified official process has been established. Built on the foundation of the 2019 Labor Code, Decree 219 is not merely an amendment but a complete replacement and consolidation of all previously scattered regulations, creating an entirely new legal framework. From the definition of job positions and the authority of state agencies to every detail within the application dossiers and processing timelines, everything has been redefined with precision.

For managers, human resources professionals, and legal experts, thoroughly understanding and mastering these changes is not just a matter of compliance. It is a critical factor in building effective human resource strategies, avoiding legal risks, and ensuring that business operations continue without interruption.

I. Summary of the Most Critical Changes for Businesses

For busy leaders, these are the core points to grasp immediately:

1. A Single, Unified Document: Decree 219 completely replaces the regulations concerning foreign labor found in Decree 152/2020, Decree 70/2023, and even a portion of Decree 128/2024. Now, businesses need only to reference a single source.
2. Authority Centralized at the Provincial Level: The Chairman of the Provincial People’s Committee is the final decision-maker for all procedures, from the new issuance and renewal to the revocation of work permits and exemption certificates.
3. Quantified Standards for Job Positions: The roles of “Manager,” “Executive Director,” “Expert,” and “Technical Worker” have been redefined in great detail, with specific requirements for academic qualifications and years of experience.
4. Clearly Defined Dossiers and Processing Times: The Decree specifies the list of documents for each procedure and sets clear processing timelines (e.g., 07 working days for a new work permit), creating a transparent legal basis for businesses to follow.
5. Online Dossier Submission: Submitting applications is now officially permitted through the National Public Service Portal, paving the way for the digitalization of administrative procedures.

To ensure authenticity, businesses can consult the full text of Decree No. 219/2025/ND-CP on the Government’s official electronic portal.

II. A Before-and-After Comparison of Regulations

To clearly illustrate the regulatory shift, the following comparison table directly contrasts the old and new provisions on the most important aspects.

III. In-Depth Analysis of General Provisions (Chapter I – The Foundation)

Chapter I of Decree No. 219/2025/ND-CP lays down the foundational principles that shape all subsequent detailed regulations.

1. Scope and Applicable Subjects (Articles 1, 2)

Decree 219 clearly defines its scope to cover all matters related to work permits (WPs) and work permit exemption certificates. Additionally, Article 2 lists a very broad range of work arrangements for foreign employees, from traditional labor contracts and intra-company transfers to more complex forms such as service providers, service offerors, and participants in bidding packages or projects. This demonstrates that the law now covers nearly every conceivable scenario, leaving no legal “gray areas.”

2. New Definitions of Job Positions (Article 3) – The Core of the Change

This is one of the most impactful changes affecting a company’s dossier preparation process. The standards have been clearly “codified”:

• Manager: Must be an enterprise manager as defined by the Law on Enterprises or the head/deputy head of an agency or organization. This requires official documents proving the title.
• Executive Director: Not only the head of a unit (branch, representative office) but must also prove at least 3 years of experience in a relevant executive role.
• Expert: The requirements for a university degree or higher and experience (2 years) are clearly stated. Notably, priority is given to experts in high-tech, finance, and innovation, who only require 1 year of experience if they hold a relevant university degree. This reflects Vietnam’s policy of selectively attracting talent. Furthermore, specific cases like artists and athletes are also clearly defined.
• Technical Worker: Two options are provided for verification: (1) Have been trained in a technical field for at least 1 year AND have 2 years of experience; or (2) Have at least 3 years of practical experience. This provides flexibility for skilled workers who may not have formal training credentials.

3. Authority and Delegation (Article 4)

Decree 219 ends the previous fragmentation of authority. Consolidating decision-making under one authority—the Chairman of the Provincial People’s Committee—helps standardize the process. Importantly, the Decree also clarifies that if an employee works in multiple provinces, the authority will belong to the Provincial People’s Committee where the employer’s head office is located. This resolves a significant issue for large-scale enterprises.

4. The Unchanged Requirement for Consular Legalization (Article 5)

The requirement for Consular Legalization of foreign-issued documents and their certified translation into Vietnamese remains a mandatory and re-emphasized rule. This is a stage where businesses often make mistakes and must be particularly careful to avoid dossier rejection.

IV. Detailed Guide to Procedures and Dossiers (Chapters II & III – An Actionable Handbook)

This section provides the most detailed implementation guide, serving as a clear checklist for a company’s HR and legal departments.

1. For Work Permit Exemption Certificates (Chapter II)

a. Overview of Exemption Cases (Article 7)

The Decree has systemized and clarified a long list of exemption cases, with key points including:

• Owners/capital-contributing members with a capital contribution of VND 3 billion or more.
• Foreigners married to Vietnamese citizens and residing in Vietnam.
• Intra-company transferees within 11 service sectors under Vietnam’s WTO commitments.
• Managers, executive directors, experts, and technical workers who work in Vietnam for a cumulative period of less than 90 days within a year.
• Individuals responsible for establishing a commercial presence.
• Many other cases related to education, journalism, volunteering, etc.

b. Procedure for a New Exemption Certificate (Articles 8, 9, 10)

• Required Dossier:
  • An application letter following Form No. 01.
  • A health check certificate (valid for 12 months).
  • Two color photos (4x6cm, white background, no glasses).
  • A certified copy of a valid passport.
  • Documents proving eligibility for one of the exemption cases.
• Process and Timelines:
  • Submission: At least 10 days and no more than 60 days before the intended start date.
  • Processing Time: The competent authority will issue the certificate within 03 working days.
  • Validity: A maximum of 02 years.

c. Re-issuance and Renewal Procedures

• Re-issuance (Articles 11-14): Applies when the certificate is lost or damaged. The dossier is simpler (only requiring an application letter and documents proving any changes, if applicable). The processing time is 03 working days.
• Renewal (Articles 15-17): The dossier is similar to a new application. It must be submitted at least 10 days and no more than 45 days before expiry. The processing time is 05 working days.

2. For Work Permits (Chapter III)

a. Dossier for a New Work Permit (Articles 18, 19, 20)

This is the most complex and critical dossier, which includes:

• An application letter from the employer, which now incorporates the report explaining the demand for foreign labor, following Form No. 03.
• A health check certificate (valid for 12 months).
• Two color photos (4x6cm).
• A certified copy of a valid passport.
• Written approval of the demand for foreign labor (if applicable, depending on local procedures after Decree 128 is replaced).
• Documents proving the job position (most important):
  • Manager/Executive Director: Company charter, business registration certificate, appointment decision, etc.
  • Expert: University degree and written confirmation of experience (2 years or 1 year, depending on the case).
  • Technical Worker: Training degree/certificate (1 year) and confirmation of experience (2 years), OR confirmation of experience (3 years).
• Note: A previously issued work permit or exemption certificate can be used as a substitute for documents proving experience.

b. Procedure and Timelines (Articles 21, 22)

• Submission: At least 10 days and no more than 60 days before the intended start date.
• Processing Time: The competent authority will issue the work permit within 07 working days.
• Validity: A maximum of 02 years, and cannot exceed the term of the contract or other related documents.

c. Re-issuance and Renewal Procedures

• Re-issuance (Articles 23-26): Applies when the work permit is lost or damaged. The dossier includes an application letter (Form No. 03), photos, and supporting documents (if any). The processing time is very fast: 03 working days.
• Renewal (Articles 27-29): The dossier is similar to a new application. It must be submitted at least 10 days and no more than 45 days before expiry. The processing time is 10 working days.

Completing these procedures is the critical legal basis for foreign employees to proceed with applying for a temporary residence card, ensuring stability in their work and life in Vietnam.

V. Provisions on Revocation and Implementation (Chapters IV & V)

1. Revocation of Work Permits and Exemption Certificates (Articles 30-33)

The Decree clearly specifies the cases for revocation, including: expiry, termination of contract, fraudulent content, cessation of the enterprise’s operations, deportation of the employee, or criminal prosecution. The revocation procedure requires the employer to return the document within 15 days from its expiry date.

2. Transitional Provisions and Effect (Articles 34, 35)

This is a crucial provision that provides peace of mind for businesses. All work permits and exemption certificates issued under the old regulations will remain valid until their expiration date. When re-issuance or renewal is needed, businesses will follow the provisions of Decree 219. This ensures there is no sudden disruption for the existing foreign workforce.

3. Responsibilities of State Agencies (Article 36)

Decree 219 clearly assigns responsibilities to each agency, creating synchronized coordination:

• Ministry of Home Affairs: To lead and manage the database.
• Ministry of Public Security: To coordinate on security and order, and issue Criminal Record Certificates.
• Ministry of Industry and Trade: To provide guidance on intra-company transfers.
• Specialized Ministries (Culture, Sports & Tourism; Education & Training, etc.): To provide guidance on confirmation criteria for specific positions.
• Provincial People’s Committees: To bear overall responsibility at the local level.

4. Official Government Forms

The appendix to this Decree includes the following important forms:

• Form No. 01: Application for issuance/re-issuance/renewal of a work permit exemption certificate.
• Form No. 02: Work permit exemption certificate.
• Form No. 03: Document explaining the demand for foreign employees and application for issuance/re-issuance/renewal of a work permit.
• Form No. 04: Work permit template.

Decree 219/2025/ND-CP has officially established a new paradigm—a more comprehensive, detailed, transparent, and stringent set of rules for the employment of foreign labor in Vietnam. The consolidation of documents, clarification of definitions, and establishment of specific processing timelines are significant advancements that demand swift adaptation from the business community. This is a golden opportunity for companies to review their entire processes, standardize their dossier systems, and train their HR teams.

Applying a new and detailed legal document like Decree 219 requires in-depth research and careful execution at every step. To support businesses through this critical transition, Vina Boueki offers expert consulting services and support for foreign employees (including applying for and renewing Work Permits, Temporary Residence Cards, etc.) to ensure all procedures are carried out accurately, efficiently, and in absolute compliance, turning legal challenges into an operational advantage.