財務・税務20 min read

Vietnam's Personal Income Tax (PIT): Expatriate Taxation and Social Insurance

Vietnam's Personal Income Tax (PIT): Expatriate Taxation and Social Insurance

An Expatriate's Vietnamese Personal Income Tax Changes Entirely on "Resident or Not"

For Japanese companies sending expatriates to Vietnam, personal income tax (PIT) and social insurance are critical issues that bear directly on both the individual's take-home pay and the company's labor costs. Yet misconceptions remain deeply rooted—"part of the salary is paid in Japan, so it has nothing to do with the local side," or "a short business trip is not taxed"—and cases of being hit later with large back taxes and late-payment interest are endless.

The first thing determined in Vietnam's PIT is whether that expatriate is, for tax purposes, a "resident" or a "non-resident." This single classification entirely changes the scope of income subject to tax, the tax rates applied, and the filing method. This article organizes, from the practical standpoint of managing expatriates, everything from the criteria for determining residency, the progressive tax rates and the various deductions, the in-kind benefits that are taxed, through to the social insurance that has been mandatory for foreigners as well since the end of 2018.

Determining Resident vs. Non-Resident Status

In Vietnam, you become a "resident" for tax purposes if you fall under any one of the following: (1) you stay in Vietnam for a total of 183 days or more within a calendar year or within 12 consecutive months from the date of entry; (2) you have a permanent place of residence in Vietnam (a registered habitual abode); or (3) you stay for a total of 183 days or more in the tax year at a residence held under a lease—any one of these.

What Changes Between Resident and Non-Resident

A resident is taxed on worldwide income, with progressive rates of 5–35% applied. The salary borne by the Japanese head office (so-called home-country pay) is also subject to filing for the portion corresponding to work performed in Vietnam. A non-resident, by contrast, is taxed only on Vietnam-source income, and employment income is subject to a flat proportional rate of 20%. Care is needed because the classification can change across years—a non-resident in the first year of a short assignment that does not reach 183 days, and a resident from the following year.

Progressive Tax Rates and Calculating Taxable Income

A resident's employment income is subject to a seven-bracket progressive scale according to monthly taxable income.

The progressive tax rates of Vietnam's personal income tax (resident, employment income)

The Structure of the Tax Brackets

Monthly taxable income up to VND 5 million is taxed at 5%, VND 5–10 million at 10%, VND 10–18 million at 15%, VND 18–32 million at 20%, VND 32–52 million at 25%, VND 52–80 million at 30%, and above VND 80 million at 35%. As with Japan, it is a marginal-progressive method, where the higher rate applies only to the portion exceeding each bracket.

Personal Deduction and Dependent Deduction

When calculating taxable income, a deduction of VND 11 million per month (VND 132 million per year) is allowed for the individual, and VND 4.4 million per month for each dependent. To receive the dependent deduction, you must register the dependents and submit supporting documents, on the condition that the spouse, children, or parents meet certain income requirements. In addition, the individual's portion of mandatory social insurance contributions and certain charitable donations are also eligible for income deductions. Note that discussion continues over revising the amounts of the personal and dependent deductions in line with rising prices and wage levels, and any revision would affect the calculation of an expatriate's take-home pay. Reviewing the deduction assumptions at the timing of a salary revision or a bonus payment leads to accurate withholding with neither excess nor shortfall.

While these deductions apply to employment income and business income, non-salary income such as dividends, interest, real-estate transfers, and capital gains is each subject to its own fixed rate (mostly around 0.1–5%), with no personal deduction applied. If an expatriate earns investment income in Japan or Vietnam, the tax treatment must be examined separately for each income category.

The Treatment of "In-Kind Benefits" Specific to Expatriates

An expatriate's package includes a variety of in-kind benefits (fringe benefits) such as housing, children's education costs, home-leave travel, and a car. The line between what is taxable and non-taxable here greatly affects the estimate of expatriate costs.

What Is Taxed and What Is Not

A company-borne housing allowance is taxable, but there is a special rule capping it at 15% of taxable income (excluding the housing cost). Children's tuition—a certain amount for schooling within Vietnam (or in the home country)—may be treated as non-taxable. An annual home-leave airfare for the individual and family, relocation costs on assignment and repatriation, and certain travel allowances are also typical examples treated as non-taxable. However, the requirements and caps are detailed, and without supporting documents the treatment turns to taxable, so putting in place an expatriate policy and settlement practice is essential.

Tax Equalization and Gross-Up

Many Japanese companies adopt "tax equalization" so that the individual's tax burden does not increase because of the assignment, with the company bearing the Vietnamese PIT on the employee's behalf. In this case, the tax the company bears is itself regarded as additional salary (an economic benefit), so PIT is levied on that portion as well, making a gross-up calculation that builds in the tax amount necessary. A flawed design of the net-pay guarantee generates labor costs beyond what was assumed.

Social Insurance Made Mandatory for Foreigners as Well

Since December 2018, Vietnam's mandatory social insurance (SI) has applied to foreign workers who meet certain requirements as well. The scope covers foreigners who hold a work permit or a practice certificate and who enter into a labor contract of one year or more with a Vietnamese company.

Illustration of the social insurance contribution rates for foreign expatriates (employer and employee portions)

Contribution Rates and Ceilings

Social insurance (retirement and survivors) is basically 14% for the employer and 8% for the employee, and health insurance (HI) is 3% for the employer and 1.5% for the employee. Unemployment insurance (UI) does not apply to foreigners. The salary used as the basis for calculating contributions has a ceiling, with social and health insurance capped at 20 times the base wage. The new Social Insurance Law enacted in 2024 (effective July 2025) has revised the details of the system, so the latest rates and ceilings need to be confirmed.

The Issue of the Absent Japan–Vietnam Social Security Agreement

As of 2024, no social security agreement is in force between Japan and Vietnam. As a result, a structure can arise in which an expatriate is enrolled in both Japan's pension and Vietnam's social insurance, leading to a double burden of contributions. This is a factor that inflates assignment costs compared with countries that have an agreement, and it is a point that cannot be overlooked when designing the assignment package.

The Practice of Filing and Payment, and Adjusting Double Taxation

The company withholds from salary and remits each month (or quarterly). A resident performs an annual finalization after the year ends and, in principle, settles by the end of March of the following year (or within 12 months of the date of entry). Payment presupposes obtaining an individual tax code (MST).

Japan and Vietnam have a tax treaty, and double taxation on the same income is adjusted through the foreign tax credit and other mechanisms. For short-term business travelers, if the requirements for the treaty's "short-stay exemption (the 183-day rule and so on)" are met, taxation in Vietnam may be exempted; however, the conclusion changes depending on who bears the salary cost and on the presence of a PE, so a case-by-case examination is necessary.

The PE Risk Lurking in Short Business Trips

You cannot relax just because it is a short business trip. If a traveler repeatedly and continuously conducts contract negotiations or provides services in Vietnam, the head office may be deemed to have a permanent establishment (PE) in Vietnam, and corporate taxation may reach the head-office level. If a PE is recognized, the premise for the short-stay exemption also collapses, and the traveler's individual salary, too, can become taxable. In a phase of expanding the local business on a travel basis, considering early on a switch to assignment or local incorporation—and organizing the structure together with the practice of establishing a local entity in Vietnam and the foreign-investment regulations—leads to containing tax risk.

The Social Insurance Benefits Foreigners Can Receive

The double burden of contributions tends to be a source of dissatisfaction on the expatriate's side, but foreigners, too, can receive certain benefits. A representative one is the lump-sum retirement benefit that can be claimed when leaving Vietnam (end of the labor contract, repatriation), received as a single payment in an amount corresponding to the contribution record. Besides this, occupational accident benefits for work-related injury or illness, and benefits related to maternity and sickness, are also covered under the system. Because the lump-sum claim on repatriation is not paid unless claimed, performing it without fail as part of the resignation procedure adds to the expatriate's own sense of fairness.

Common Mistakes in Withholding and Annual Finalization

Back taxes on expatriates mostly arise not from bad faith but from "not knowing." Grasping the typical errors that recur in practice is the greatest preventive measure.

Failure to Report Salary Paid in Japan

The most common is failure to report the salary that the Japanese head office pays in Japan (split payroll). For a resident, the Japan-paid portion corresponding to work in Vietnam must also be reported in Vietnam as worldwide income. A state of "reporting only the locally paid portion" is a point that is invariably raised in an audit.

Misvaluing In-Kind Benefits and Lacking Supporting Documents

The non-taxable allowances for housing, tuition, home-leave travel, and the like have detailed requirements and caps, and without supporting documents (contracts, receipts, boarding passes, and so on) the treatment turns to taxable. A failure to gross up the tax the company has borne (tax equalization) is also raised later as an understatement of the tax base. A framework that spells out the taxable and non-taxable treatment in the expatriate policy and centrally manages the settlement documents is effective.

Checkpoints for Expatriate Taxation (Comparison Table)

Organizing the main differences between residents and non-residents gives the following.

Item

Resident

Non-Resident

Days of stay

183 days or more

Fewer than 183 days

Subject to tax

Worldwide income

Vietnam-source income

Rate on salary

Progressive 5–35%

Flat 20%

Various deductions

Available

None in principle

Final return

Required (annual finalization)

Often completed by withholding

An expatriate's PIT and social insurance form an area where three things intertwine: the individual's take-home pay, the company's burden, and compliance. Unless you design as one whole the assessment of residency classification, the taxability determination of in-kind benefits, the gross-up calculation, and the application of social insurance, you will invite unexpected costs and back taxes. Solara & Co supports everything from the tax simulation of the assignment package, the practice of monthly withholding and annual finalization, through to putting the expatriate policy in order—from the perspectives of both the Japanese and Vietnamese sides. We also recommend designing the local entity's overall labor costs to be consistent with the practical points of Vietnamese labor law and with taxation at the corporate level.

FAQ

Frequently asked questions

ベトナムの個人所得税で居住者と非居住者はどう判定しますか?

次のいずれかで居住者になります。(1)暦年または入国から連続12か月で通算183日以上の滞在、(2)ベトナムに恒久的住所を持つ、(3)課税年度に通算183日以上、賃貸住居に滞在。居住者は全世界所得が累進5〜35%で課税され、日本本社が払う給与のうちベトナム勤務対応分も申告対象です。非居住者はベトナム源泉所得のみで、給与は一律20%です。

駐在員の給与にはどのくらいの税率がかかりますか?

居住者の給与所得は7段階の超過累進です。月額課税所得500万ドンまで5%、〜1,000万10%、〜1,800万15%、〜3,200万20%、〜5,200万25%、〜8,000万30%、8,000万ドン超は35%。本人基礎控除は月額1,100万ドン(年1億3,200万ドン)、扶養家族は一人月額440万ドンの控除があります。非居住者は一律20%で控除は原則ありません。

住宅手当や子女学費などの駐在員手当は課税されますか?

会社負担の住宅手当は課税ですが、住宅費を除く課税所得の15%を上限とする特例があります。子女学費(一定範囲)、本人・家族の年1回の一時帰国航空券、赴任・帰任の引越費用などは要件を満たせば非課税です。ただし上限と証憑要件が細かく、証憑がなければ課税扱いになるため、駐在員規程と精算実務の整備が欠かせません。

外国人駐在員もベトナムの社会保険に加入する必要がありますか?

2018年12月から、労働許可証を持ち1年以上の労働契約を結ぶ外国人にも強制社会保険が適用されます。社会保険(退職・遺族)は事業主14%・本人8%、医療保険は事業主3%・本人1.5%が基本で、失業保険は外国人に適用されません。算定基礎は基礎賃金の20倍が上限です。日越間に社会保障協定がないため、日本の年金との二重負担が生じ得る点に注意が必要です。

駐在員税務でよくある追徴の原因は何ですか?

最も多いのが日本払い給与(スプリット・ペイロール)の申告漏れです。居住者はベトナム勤務対応の日本払い分も全世界所得として申告義務があります。次に、住宅・学費・帰国旅費の非課税枠の証憑不足や評価誤り、会社が肩代わりした税金のグロスアップ漏れです。駐在員規程で課税・非課税を明文化し精算証憑を一元管理することが最大の予防策になります。

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