Case Overview
A mid-sized German Mittelstand manufacturer sought to establish a wholly foreign-owned enterprise (WFOE) in Binh Duong Province (now part of Ho Chi Minh City since 1 July 2025) to serve the ASEAN manufacturing supply chain. The client required full regulatory structuring, investment licensing, and tax optimization before breaking ground.
Challenges
The project involved coordinating investment registration under the Law on Investment, negotiating land-use rights with the industrial zone authority, structuring the enterprise for preferential corporate income tax rates, and establishing transfer pricing documentation compliant with Vietnam’s Decree 132/2020/ND-CP, which applied at the time (it has since been replaced by Decree 255/2026/ND-CP with effect from 1 July 2026).
ECOVIS Solution
ECOVIS Vietnam Law handled the full market-entry legal structure: IRC and ERC registration, charter preparation, bank account establishment, and tax registration. The team coordinated with ECOVIS Germany to align the holding structure with German CFC rules and ensure cross-border compliance.
Outcome
The factory received all required approvals within 14 weeks. The client achieved a 10-year CIT incentive rate of 10% under the high-tech enterprise classification, significantly reducing its effective tax burden during the investment payback period.
See our Manufacturing Investment Vietnam guide and German Desk, or contact our team to discuss your project.
