Investor tools

What an overseas franchisor actually pays

Pick a market and an ownership type. You get every tax that applies to you as a franchisor granting rights into that country — who bears it, at what statutory rate, and which agreement reduces it. Every rate links to the government that levies it.

⚠ A free trade agreement will not reduce your royalty tax

An FTA cuts customs duty on goods — equipment, ingredients, packaging, fit-out. It does nothing to a royalty. The instrument that reduces withholding tax on royalties and service fees is a double taxation agreement, a separate treaty with a separate claim process. Both are listed below, separately, and never merged.

This is a map of which taxes exist, not advice on your facts. Statutory rates are the only figures a government publishes and stands behind; what you actually pay turns on treaty eligibility, the documents filed before payment, and how each fee stream is characterised in your agreement. Take this to an adviser and pay for judgement, not for orientation.

Market

Ownership type

🇻🇳 Vietnam · Master Franchise

Every head that bites on a Master Franchise arrangement.

Foreign Contractor Tax — CIT on royalties

10%
Borne by: Franchisor (overseas)Verify officially

Circular 103/2014/TT-BTC. Royalties, trademark licences and franchise fees paid offshore carry a 10% deemed CIT, withheld and remitted by the Vietnamese payer. The classification line matters: a payment that licenses IP is a royalty at 10%, even where the contract calls it a service fee (services are 5%).

Source: Circular 103/2014/TT-BTC (Foreign Contractor Tax)

Foreign Contractor Tax — VAT component

0% on IP / technology transfer; 5% on services
Borne by: Franchisor (overseas)Verify officially

Transfer of technology and of intellectual property rights is VAT-exempt, so a pure trademark/know-how licence carries CIT only. A mixed contract that also supplies training, marketing or systems support pulls the service element into the 5% VAT band — split the consideration in the agreement or the whole fee risks the higher treatment.

Source: General Department of Taxation — VAT on foreign contractors

Corporate income tax (local entity)

20%
Borne by: Franchisee (local)Verify officially

Standard rate on the local operating company's profits.

Source: General Department of Taxation

VAT on local sales

10% standard
Borne by: Franchisee (local)Verify officially

A temporary two-point reduction to 8% has applied to many goods and services under successive National Assembly resolutions. Check whether the current resolution period is still running before pricing.

Source: Ministry of Finance / General Department of Taxation

Import duty on goods and equipment

MFN tariff; 0% on most lines under FTAs
Borne by: Franchisee (local)Verify officially

Import VAT applies on top of duty. Preferential rates require a valid certificate of origin under the relevant agreement — the paperwork is the benefit; without it the MFN rate applies.

Source: General Department of Vietnam Customs

What changes at this ownership type

MOIT registration must be completed before the master agreement is signed. The master franchisee pays local CIT and VAT on its own sub-franchise income; your royalty still suffers the 10% FCT on the way out.

Taxable presence risk:MediumHow likely your own activity in this market is to create a permanent establishment — which pulls local corporate tax and transfer pricing into scope on top of withholding.

Registration required before fees can flow

A foreign franchisor must register with the Ministry of Industry and Trade before granting rights in Vietnam (Decree 35/2006/ND-CP), and disclose at least 15 working days before signing.

📦 Free trade agreements — duty on goods

These reduce or remove customs duty on what you ship in. They do not touch royalties.

CPTPP

11 Asia-Pacific economies + the UK

Tariff elimination on ~99% of tariff lines at full implementation

RCEP

10 ASEAN members + China, Japan, Korea, Australia, NZ

Reduces or eliminates ~92% of tariffs over 20 years

ATIGA

ASEAN

Near-zero intra-ASEAN tariffs on most goods

EVFTA

European Union

Progressive elimination of duty on almost all lines

UKVFTA

United Kingdom

Carries EVFTA terms into UK–Vietnam trade

💸 Double taxation agreements — tax on royalties

This is the instrument that changes what you bank on a royalty stream.

Treaty network

~80 double taxation agreements

Typical royalty rate under treaty

10%, and 5% under a few treaties

A treaty rate is not automatic. The recipient must file a tax residence certificate and the treaty notification with the Vietnamese payer before the payment, or the domestic 10% is withheld and reclaiming it is slow.

General Department of Taxation (Ministry of Finance)

Tax authority: General Department of Taxation (Ministry of Finance) · Customs authority: General Department of Vietnam Customs · Rates reviewed: 2026-08-25

Country tax detail is published in English only. Rates and legal rules are not machine-translated here, because a mistranslated tax rule is worse than an untranslated one.

Questions worth asking first

No. A free trade agreement reduces customs duty on goods — equipment, ingredients, packaging, fit-out. It does nothing to the tax on a royalty. The instrument that reduces withholding tax on royalties and service fees is a double taxation agreement, which is a separate treaty with a separate claim process. This tool lists both, separately, because budgeting a zero royalty tax on the strength of an FTA is one of the most expensive mistakes a first-time international franchisor makes.