Vietnam regards tourism development, especially resort tourism, as a key economic sector. The government has issued numerous incentive policies to attract investment in resort areas, in line with sustainable development and environmental protection goals. According to the 2017 Law on Tourism, tourism businesses are entitled to the highest level of investment incentives and support under the State’s investment promotion policies. These incentives focus mainly on tax, land use, and investment procedure support and are applicable when the project meets the conditions regarding eligible sectors or locations as stipulated by current laws.

Below is a comprehensive summary of the latest investment incentive policies applicable to resort tourism projects in Vietnam as of 2025, including: corporate income tax incentives, exemptions and reductions of related taxes and fees, land use incentives (land rental, land use fees, land lease terms), eligibility conditions, and the procedures and competent authorities for recognition of such incentives.

1. Overview of Investment Incentive Policies

Investment incentive policies for resorts in Vietnam are governed by several key legal instruments, including the 2020 Law on Investment and its guiding decrees. These incentives aim to encourage investment in areas with difficult socio-economic conditions and in key tourism zones.

2. Types of Investment Incentives for Resorts

2.1. Corporate Income Tax (CIT) Incentives

Investors in resort projects may enjoy various tax incentives if their projects fall within the categories eligible for investment incentives under the Law on Investment. Tax incentives include preferential CIT rates (lower than standard), CIT exemptions or reductions for a defined period, import duty exemptions for goods used to create fixed assets, and land-related tax exemptions/reductions.

Standard CIT rate:

Currently, the general CIT rate is 20% on taxable income. Resort projects not meeting the conditions for incentives (e.g., not located in eligible areas or not operating in incentivized sectors) are subject to the standard rate of 20%. (Clause 6, Article 1, Law amending the Law on Corporate Income Tax 2013)

Preferential CIT rates based on location (Clause 7, Article 1, Law amending the Law on Corporate Income Tax 2013):

  • Areas with especially difficult socio-economic conditions (e.g., island districts, remote areas) or within economic zones and high-tech zones: 10% CIT for 15 years. This is the highest preferential level for new projects in such areas.
  • Areas with difficult socio-economic conditions: 17% CIT for 10 years for new projects in these locations. After the preferential period, the rate reverts to 20%.

Special preferential rates for particularly significant projects: For resort projects classified as particularly significant (e.g., in specially incentivized sectors, with substantial capital investment), higher incentives may be available by decision of the Prime Minister. According to Clause 2, Article 20 of the 2020 Law on Investment, special tax incentives may include up to a 50% reduction from normal preferential rates and an extension of the preferential period up to 1.5 times the standard (up to 15 additional years). However, this mechanism applies only to truly exceptional projects (e.g., high-tech, innovation-based) as decided by the Prime Minister.

Tax exemption and reduction period (based on Articles 11 and 12 of Circular 96/2015/TT-BTC, amending Clause 1, Article 19 of Circular 78/2014/TT-BTC):

  • In areas with especially difficult socio-economic conditions or economic zones: CIT exemption for 4 years, followed by a 50% CIT reduction for the next 9 years. For example, income from a new resort project in such areas will be tax-exempt for the first 4 years from the time of taxable income, and subject to only 5% (half of the 10% preferential rate) for the next 9 years. From year 15 onwards, the rate reverts to 10%, then to the standard 20% after the incentive period.
  • In difficult areas (17%/10 years as noted above): typically exempted for 4 years, with a 50% reduction for the next 5 years (i.e., 8.5% CIT rate), then 17% until the end of the 10-year preferential term.
  • For sector-based incentives only (without location-based incentives): reduced incentive level applies, e.g., 2 years of exemption and 50% reduction for the following 4 years for certain incentivized sectors. (Note: Resort tourism is not listed as a specially incentivized sector under the Law on Investment, so it primarily benefits from location-based incentives.)

2.2. Land Use Incentives

Land-related incentives play a crucial role in attracting resort investment due to the large land areas and long payback periods involved. When the State leases land to investors (annually or one-off payment), various exemptions and reductions apply based on the project’s location and characteristics:

Land rental exemptions/reductions (Clause 2, Article 39, Decree 103/2024/ND-CP):

  • Exemption during construction period: All investment projects are generally exempt from land rental during the initial construction phase (before land is put into commercial use). Under current regulations, this exemption can last for up to 3 years from the land lease decision.
  • Additional exemptions based on location:
    • In difficult socio-economic areas: 3 years exemption after construction.
    • In especially difficult areas: 7 years exemption after construction.
  • Combined location and sector-based incentives: If a project is both in an incentivized sector and location, greater exemptions may apply. For example, projects in education, healthcare, or environment sectors located in especially difficult areas may get 11 years of land rental exemption; projects in specially incentivized sectors may be exempted for up to 15 years. However, as resort tourism is not classified as a specially incentivized sector, standard resort projects typically enjoy land incentives based on location only.

Incentives in Economic Zones: Many resort projects are located in coastal economic zones or national tourism areas (often managed as economic zones). Special land incentives apply:

  • In difficult areas: 11 years exemption post-construction.
  • In especially difficult areas: 13 years exemption post-construction.

Post-exemption reductions: After the exemption period, land rental payments begin. In some cases, a 50% reduction is granted for subsequent years.

Reduction of land use fees: Projects in incentivized sectors or areas may qualify for reductions in land use fees, subject to current government regulations.

No land use right auction: An important indirect incentive is the exemption from public auction or bidding for land use rights. While land allocation to businesses typically requires an auction, projects eligible for investment incentives and fitting land-use planning may be leased directly by the State without an auction (Articles 124, 125, Land Law 2024).

In addition to formal exemptions, investors may receive local government support in site clearance and infrastructure development for the project (Clause 1, Article 18, Law on Investment 2020).

3. Financial Obligations and Eligibility Conditions

To enjoy investment incentives, resort projects must meet certain financial obligations and eligibility criteria:

3.1. Financial Obligations

  • Full tax compliance: Investors must declare and pay all applicable taxes, fees, and charges in a timely and accurate manner, including but not limited to: CIT, VAT, non-agricultural land use tax, land rental, land use fee (if any), business license fee, and social insurance for employees.
  • Capital contribution commitments: Investors must contribute capital in accordance with the registered schedule and ratio stated in the Investment Registration Certificate.
  • Financial reporting obligations: Resort project companies must fully comply with accounting and tax laws regarding financial statement preparation and submission.

3.2. Eligibility Conditions

  • Minimum capital requirement (if any): Some localities or economic zones may impose a minimum capital threshold for resort tourism projects to access certain incentives. For instance, to qualify for the Prime Minister’s special incentives, a project may need to disburse over VND 30,000 billion within 3 years.
  • The project must comply with tourism and land-use planning: The resort must align with approved tourism development plans and land-use plans.
  • Environmental protection requirements: Given the close link between resort tourism and ecosystems, projects must comply with the 2020 Law on Environmental Protection. Generally, medium to large resort projects must undergo an environmental impact assessment (EIA) and receive approval before implementation.
  • Other compliance conditions: Projects must observe labor laws (e.g., prioritizing local labor, adhering to foreign labor quotas), meet all financial obligations, and follow the committed project schedule.

4. Procedures to Access Incentives

To obtain investment incentives, investors must complete the following steps:

  1. Investment policy approval (if required): For large-scale resort projects or those involving significant land use, prior approval for investment policy must be obtained (Article 29, Law on Investment).
  2. Investment Registration Certificate (IRC): This formalizes the project’s registration and eligibility for incentives (Article 23, Law on Investment).
  3. Land procedure implementation: After obtaining the IRC, investors work with the Department of Natural Resources and Environment to lease or receive land.
  4. Construction and environmental procedures: Investors must obtain necessary construction permits and complete detailed EIA procedures if not done during the policy approval phase.
  5. Tax notification: The enterprise must notify the tax authority of the commencement of its preferential tax period.

Conclusion

Vietnam’s 2025 investment incentive policies for resort projects offer numerous attractive opportunities for investors. With a clear legal framework and a wide range of incentives, investing in resort development has never been more favorable. However, to maximize these incentives, investors must thoroughly study and comply with all legal requirements.

For detailed consultation on resort investment incentives, please contact the legal experts at Harley Miller Law Firm or register to receive the full guidance dossier.

Refer another related article Resort Construction Planning in Vietnam: A Comprehensive Guide for 2025

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