Vietnam Profit Repatriation the complete guide

Repatriation channels

Foreign investors in Vietnam can repatriate returns through three main channels: (1) dividends from after-tax profits; (2) capital remittance (original capital and any gain on transfer); (3) royalties, interest, and fees for services.

Each channel has specific tax treatment and SBV reporting requirements. Dividends are subject to 0% withholding tax under Vietnamese domestic law (or treaty rate where applicable). Capital remittance is generally tax-free (subject to capital gains tax on the gain). Royalties and interest are subject to FCT or treaty-rate withholding.

Repatriation requires: CIT finalisation for the relevant year, the SBV notification, the bank's remittance processing, and the documentation package.

Dividend distributions

Dividends are paid from after-tax profits. A Vietnamese company can only pay dividends if it has accumulated after-tax profits.

Dividend withholding tax: 0% under Vietnamese domestic law. Most DTAs also reduce to 0% (subject to conditions). The Vietnamese payer is responsible for declaring and remitting the 0% withholding.

Dividends cannot be paid from share capital. The share capital must be maintained at the level registered in the ERC; dividends are paid from retained earnings.

Quarterly dividends are permitted if the company has accumulated profits. Interim dividends require a board resolution and confirmation of profitability.

Capital remittance

Capital remittance is the return of the original investment capital. The remittance is processed by the bank with SBV notification.

Capital gains tax: capital gains from the transfer of capital in a Vietnamese company are taxed as ordinary CIT at 20% on the actual gain (transfer price less cost of capital). The transfer must be declared and the tax paid.

Capital remittance is not subject to withholding tax. The remittance is processed based on the original capital contribution documents.

Royalty and fee repatriation

Royalty payments from Vietnam to foreign parties are subject to withholding tax under FCT (or treaty rate). The Vietnamese payer withholds and remits.

Royalty FCT: VAT 5% deemed + PIT 10% deemed (or treaty rate). The treaty rate for royalties is typically 5–10%.

Service fees for services performed partly in Vietnam are subject to FCT on the Vietnam-source portion. Services performed entirely outside Vietnam are not subject to FCT (with documentation).

Documentation required: contract, beneficiary CoR (for treaty relief), description of services, place of performance, payment evidence.

SBV reporting and approval

All capital transactions between foreign investors and Vietnam must be registered with the SBV via the company's bank. The registration includes: capital account opening, capital contribution, and capital remittance.

The SBV does not pre-approve remittance, but the bank processes the remittance based on the SBV-registered capital account. Mismatches between the registered capital and the remittance trigger queries.

Annual SBV reporting: FDI companies must file annual reports on capital, loans, and profit with the SBV. The reports are due by 31 March of the following year.

Late or incorrect SBV reporting triggers penalties and may delay future remittances.

Documentation required

Standard documentation for dividend remittance: board resolution declaring the dividend, CIT finalisation confirmation, audited financial statements (where applicable), bank account details of the recipient, and the SBV notification.

Documentation for capital remittance: original capital contribution evidence, ERC, IRC, SBV capital account confirmation, and the bank's remittance request.

Documentation for royalty remittance: royalty agreement, beneficiary CoR (for treaty relief), FCT declaration, and the bank's remittance request.

The documentation must be retained for at least 10 years and may be requested by the SBV or the GDT in the event of an audit.

Common repatriation mistakes

The most expensive repatriation mistakes: (1) failing to declare capital gains on capital transfer, (2) over-withholding on dividends (claiming treaty rate without CoR), (3) under-withholding on royalties, (4) failing to register the capital account with the SBV.

The most common avoidable penalty: late SBV reporting. The penalty is small but delays future remittances.

The most expensive avoidable penalty: failure to declare capital gains on the transfer of capital. The GDT assesses back tax, interest, and a 1–3x penalty.

Frequently asked questions

The most common questions our tax and accounting team receives about vietnam profit repatriation guide: dividends, capital, royalties.