Re-introducing debt-equity ratio control for foreign-invested enterprises?

Earlier this month (December 2012), the Prime Minister issued Directive 32 to various ministries to instruct the ministries to remove obstacles to increase investment efficiency.  The Prime Minister instructed the State Bank to focus on developing a mechanism to monitor the total amount of domestic and foreign loans in comparison with the total investment capital of foreign direct investment projects. It seems that the Prime Minister now wants to re-introduce debt-equity ratio control for foreign-invested enterprises. Before 2006, under the old Foreign Investment Law, a foreign invested enterprise’s owner equity must be at least 30% of the total investment capital of a project.

Vietnam Business Law Blog

The Government officially issued Decree 102/2026/NĐ-CP (Decree 102/2026), which introduces critical amendments and supplements to Decree 75/2019/NĐ-CP (Decree 75/2019) regarding administrative penalties for violations in the competition sector. Effective from 20 May 2026, Decree 102/2026 provides clearer enforcement guidelines and adjusts penalty frameworks, particularly for economic concentrations.

Below is a summary of the key changes introduced by Decree 102 that will directly affect M&A transactions subject to merger control (economic concentration notification) requirements in Vietnam.

In March 2026, Vietnam’s Ministry of Finance (MOF) released a draft decree (Draft Decree) implementing the Law on Personal Income Tax 2025 (PIT Law 2025) for public consultation. One proposal drew strong feedback from businesses and investors: a change to how individuals are taxed on the transfer of shares in non-public/unlisted joint-stock companies (JSCs). Following the consultation, the MOF now appears poised to step back from that change – welcome news for investors and companies engaged in M&A and private share transactions.

On 5 June 2026, the Government issued Decree 200 on private placement and trading of corporate bonds on domestic market and offering of corporate bonds on international market (Decree 200/2026). Decree 200/2026 will replace Decree 153/2020 on the same subject. In the past, Decree 153/2020 has been amended by Decree 65/2022 and Decree 8/2023. Decree 200/2026 introduces more conditions for private bond issuance.

5x debt/equity ratio

1.1.      Decree 200/2026 reflects the 5x debt/equity requirement established under the 2025 amendment to the Enterprise Law. In particular, the debt of a bond issuer (including the value of the bonds to be issued) must not exceed 5 times of the equity of such issuer as recorded in the audited financial statements of the year preceding the issuance.

On 15 May 2026, the Ministry of Finance issued Circular 55/2026/TT-BTC (Circular 55/2026), introducing a new set of forms for investment activities in Vietnam. Two specific changes in the new form of application for M&A Approval are notable for investors engaged in M&A transactions.

On 15 May 2026, the Government issued Resolution No. 66.17/2026/NQ-CP (the Resolution 66.17 or the new), slimming down the list of conditional business sectors currently set out in Appendix IV of Investment Law 2025 (the old).

Resolution 66.17 will take effect on 1 July 2026 and is set to expire on 28 February 2027, by which time the Government expects the National Assembly to formalise these adjustments through an amendment to Appendix IV. Although there would be a question about the effectiveness of the Resolution 66.17 over the Appendix 4 of Investment Law 2025 and how the investment authority will apply in practice, the investor may, in the meantime, treat the Resolution 66.17 as the working text for the next 9–10 months while following up on the law amendments.

65% or 51% simple majority voting?

Under the Enterprise Law, the quorum for a meeting of the Shareholders Meeting is met when the number of shareholders present in person and by proxy represents at least 65% of all voting shares. A decision of the Shareholders Meeting on matters which are not a super majority issue can only be passed if it is approved by a number of shareholders holding more than 65% of the number of shares entitled to vote.

Resolution 71 approving Vietnam’s accession to the WTO (Resolution 71)  provides that “[A] shareholding company is entitled to provide in its charter … the number of members [of the company] required for holding a shareholder meeting [and] … the majority vote necessary (including 51% majority) in order to pass decisions … of the shareholder meeting”.

Foreign investment in service sectors not included in the WTO Commitments

F

oreign investors interested in service sectors in Vietnam will first need to look at the commitments of Vietnam to the WTO on various sectors (WTO Commitments). If the relevant service falls into one of the service sectors committed in the WTO Commitments then the investors will more or less have an answer. If the relevant service does not fall into one of the service sectors committed in the WTO Commitments (Non-committed Services) then one would need to look at the relevant domestic laws to see if the market is open to foreign investors. Usually, if there is no express restriction on a Non-committed Services under domestic laws then a foreign investor should be able to invest in such sector. This position is reflected in Decree 108/2006 implementing the Investment Law.

Role of Joint venture agreements

The documentation for a joint venture company in Vietnam must at least include a joint venture agreement and a joint venture charter. If there is difference between the joint venture charter and the joint venture agreement, then one needs to decide which document will take precedent. Usually, in such case, the joint venture parties tend to favour the joint venture agreement for two reasons. First, the joint venture agreement is usually regarded as a private agreement between the joint venture parties and therefore needs to be respected. Second, before 2005, under the old Foreign Investment Law, a joint venture agreement has a clear legal status and would take precedent over a joint venture charter