15:30 20/01/2025

The Investment Support Fund: A strategic leap for Vietnam's economic future

By Tran Anh Son – Tax & Legal Director, Global Innovation and Investment Incentives (Gi3), Deloitte Vietnam

Decree 182/2024/ND-CP, dated 31 December 2024, establishes the Investment Support Fund, offering financial incentives to boost investment in high-tech industries, semiconductors, and AI, enhancing Vietnam’s global competitiveness.

In the face of growing global economic challenges, ranging from geopolitical instability to a slowdown in growth, attracting investments into strategic sectors has become a top priority for many nations. High-tech industries, semiconductors, artificial intelligence (AI), and innovation are not only vital for economic growth but also for establishing a country's position in the global value chain. Vietnam, a favored destination for foreign investors, is keeping pace with these trends.

With geographical advantages, a robust labor force, and a strong commitment to improving the investment environment, Vietnam continues to draw significant attention from international investors. Over the past 35 years of economic reforms and foreign investment attraction, the Vietnamese government has implemented numerous policy changes, facilitating a continuous influx of foreign capital. These efforts have transformed the country’s economic landscape. However, with fierce competition from neighboring countries such as Indonesia, Thailand, Malaysia, and India, which offer superior investment incentives, Vietnam needs strategic breakthroughs to remain attractive to investors.

After extensive study and learning from advanced economies, the government issued Decree No. 182/2024/ND-CP (Decree 182) on December 31, 2024, to establish, manage, and utilize the Investment Support Fund. Decree 182 represents a strategic initiative to demonstrate the government’s commitment to substantive investments, focusing on priority sectors, enhancing innovation, and positioning Vietnam as a hub for advanced technology. This approach aims to solidify Vietnam’s status as a preferred destination for global “eagle investors.”

Key provisions

Decree 182 introduces two primary forms of support from the Investment Support Fund: Annual expense support and Initial investment cost support. Each form targets specific industries and enterprises, aligning with sectoral development objectives.

Annual expense support applies to four groups: high-tech enterprises, enterprises having projects manufacturing high-tech products, enterprises having projects applying high technology, and enterprises investing in research and development (R&D) centers. Projects in the first three groups must typically meet a minimum investment threshold of VND12,000 billion (approx. $480 million) or achieve annual revenue of VND20,000 billion 800 million). Exceptions apply to projects in strategic sectors such as semiconductor manufacturing, integrated circuits, and AI data centers, which require only VND6,000 billion (approx. $240 million) in investment or VND10,000 billion (approx. $400 million) in annual revenue. Some projects with breakthrough products or technologies may qualify without meeting capital or revenue criteria.

Enterprises investing in R&D centers must commit to a minimum investment of VND3,000 billion (approx. $120 million), with at least VND1,000 billion (approx. $40 million) disbursed within three years to ensure feasibility and timely execution.

The decree specifies support percentages for different expense categories, urging enterprises to thoroughly study eligible expenses for alignment with their projects. Eligible costs include R&D, training and human resource development, fixed asset investments, high-tech product manufacturing, and social infrastructure system investments.

Initial investment cost support, on the other hand, focuses primarily on enterprises with R&D centers in strategic sectors such as semiconductors and AI. Eligibility criteria include no overdue tax liabilities at the time of application and evidence of the project’s positive impact on the innovation ecosystem.

Through the Investment Support Fund, Vietnam expands its incentive framework by introducing cost-based incentives alongside traditional profit-based incentives. This necessary shift brings flexibility and ensures effective support for priority investment projects.

Benefits for businesses

The Investment Support Fund provides significant benefits, particularly for businesses operating or planning investments in high-tech sectors. Notably, support received by businesses under this policy is exempt from corporate income tax.

Firstly, enterprises benefit from financial relief through specific support rates tailored to annual costs or initial investment costs, depending on eligibility. For instance, training and human resource development expenses may receive up to 50 per cent support, while R&D expenses may be covered up to 30 per cent. Fixed asset investments and high-tech product manufacturing expenses can receive maximum support of 10 per cent and 1 per cent, respectively, while strategic projects in sectors like semiconductors and AI may qualify for up to 3 per cent support. Social infrastructure system investments may be supported up to 25 per cent. For initial investment costs, the subsidy could be up to 50 per cent. This support structure enables businesses to focus resources on scaling production, developing new technologies, and improving competitiveness.

The policy also serves as a catalyst for innovation, particularly in high-tech industries like semiconductors and AI, by offering cash grants/subsidies for R&D and human resource development.

In addition, businesses investing in R&D centers are also empowered to build internal research capabilities, enhancing their global value chain positioning.

Besides, support from the fund not only improves operational efficiency but also elevates the enterprise’s reputation among partners and clients, creating a foundation for additional domestic and international investments.

Finally, businesses engaging in this policy contribute to Vietnam’s sustainable economic growth, fostering a stable and long-term investment environment.

Recommendations for businesses

Accessing the Investment Support Fund requires meticulous preparation and long-term strategic planning.

Enterprises should first study Decree 182 to fully understand its provisions, eligibility criteria, and the list of supported costs. This analysis helps identify project compatibility with the decree’s objectives, minimizing errors and enhancing access to support.

In addition, businesses should review their investment plans, including capital scale, projected revenue, and related expenses. Ongoing projects should be assessed against the decree’s criteria, while new projects should be planned from inception to align with eligibility requirements, particularly for critical criteria like minimum investment thresholds and disbursement timelines.

Application dossiers should be meticulously prepared, ensuring transparency and accuracy. Enterprises in high-tech sectors need to obtain certification as high-tech entities or activities, while financial reports, expense evidence, and other legal documents should be submitted in compliance with regulations.

Finally, consulting investment and tax policy experts is advisable to ensure applications and plans meet the requirements, especially for large or complex projects.

Conclusion

Decree 182/2024/ND-CP and the Investment Support Fund represent not just policy instruments for attracting investment but also foundations for advancing strategic sectors and elevating Vietnam’s position in the global economy. With thorough preparation, sound strategies, and professional support, businesses can seize the opportunities provided by this policy to scale operations, enhance competitiveness, and contribute to Vietnam’s socio-economic development.

If effectively implemented, the Investment Support Fund will act as a catalyst for attracting high-tech projects, fostering a sustainable, innovative, and globally integrated economy. This policy underscores the government’s commitment to creating the most favorable conditions for investors, domestic and international alike, to jointly develop key industries and establish Vietnam as a regional innovation hub.

*All converted figures are based on an exchange rate of $1 = VND25,000.