Export of services or payment activities? How to legally receive payment in Vietnam.

Receiving Foreign Payments in Vietnam: Where’s the Line Between Legal Business and Illegal Payment Activity?

If you receive payments from international clients — whether for marketing, IT, design, consulting, or other services — it's critical to understand the difference between two similar-looking but legally very different models.

Scenario 1. Agency Model

You Receive Funds and Forward Them to Third Parties on the Client’s Behalf

Example:

• A client pays you $10,000

• You then forward $2,000 each to five different contractors, as per the client's instructions

Sounds like a normal workflow? Unfortunately, in Vietnam, this is considered payment service provision — a strictly regulated activity that requires a license from the State Bank of Vietnam (SBV).

What the law says

This is classified as an “on-behalf payment service”, which can only be provided by:

• The State Bank of Vietnam

• Licensed commercial banks and their branches

• Licensed microfinance institutions

• The state postal operator (ViettelPost)

• No regular company, even a locally-owned LLC, is allowed to provide this service without a license

Decree No. 52/2024/ND-CP and Circular No. 15/2024/TT-NHNN explicitly include payment services in the list of regulated activities. Offering them without a license is a direct violation of the law.

Why this matters:

Banks are required to monitor all transactions. If:

• You're regularly receiving payments and forwarding them to others

• Without providing services yourself

• Your account may be flagged, frozen, or closed under AML (Anti-Money Laundering) provisions

Want to do it legally? You'll need:

• Status as an Intermediary Payment Services (IPS) provider

• At least 50 billion VND in charter capital (≈ $2 million USD)

• Adequate IT systems, data protection, and AML/KYC procedures

• Approval from the SBV — especially challenging if your company has 100% foreign ownership

Conclusion:
You cannot use the agency model without a license in Vietnam. A regular LLC cannot act as a “payment wallet.”
Doing so exposes you to serious risks: frozen accounts, fines, license revocation, banking bans, and potential criminal liability.

Scenario 2. Export of services

You Provide Services, Get Paid, and Pay Contractors from Your Revenue

This is the classic export model:

• You are the service provider with a direct contract

• You receive funds into your business account

• You pay your freelancers, designers, marketers, etc., as subcontractors

The law allows this

This is considered export of services.

• You get revenue for your own work

• You pay third parties as regular business expenses

• This is not a payment service and does not require a license

There are no special restrictions under the law.
You can use a standard 100% foreign-owned LLC. This is the default and legal model for international service providers in Vietnam.

To operate this way:

• Include the relevant service activities in your business license (IT, consulting, marketing, etc.)

• Obtain an IRC and ERC or at least an ERC

• Maintain full documentation (contracts, invoices, delivery reports)

• Subcontractor payments should be backed by signed agreements — even with foreign individuals

Taxes and Transfers

Receiving payments from clients:

• Foreign currency (USD, EUR, etc.) is allowed

• Funds go to your Vietnamese bank account

• The bank may request a contract or invoice as proof

Paying contractors:

• You can transfer funds abroad (based on contract and invoice)

• The bank must verify the legitimacy and purpose of the transfer

• Frequent transfers to individuals may raise questions — but are not prohibited

• There are no formal limits — everything must reflect real business activity

VAT: 0% for Exported Services

If you:

• Sign a contract with a foreign client

• Deliver a service consumed outside Vietnam

• And receive payment from abroad —

Then you qualify for 0% VAT.
This is legal and beneficial, backed by the 2024 VAT Law and Circular No. 219/2013/TT-BTC.

In Summary

Are you a foreign entrepreneur in Vietnam working with global clients?
Choose a legal structure:

• No “payment wallets”

• Only transparent services, contracts, and invoices

Need help with company setup, business structure, tax compliance, or cross-border payments?
Contact us — we’ll show you how to do everything right from the start.

Book a consultation with an expert on company setup in Vietnam