Tiếng Việt
中文Quick answer: Yes — but only within the scope permitted by law. The general principle is to restrict the use of foreign exchange within the territory of Vietnam (Article 22 of the Ordinance on Foreign Exchange 2005, amended 2013): all transactions and payments may not be made in foreign exchange, except in permitted cases. One permitted case is paying salaries, bonuses and allowances in foreign currency to non-residents and to resident foreigners working for that organization itself (item 14, Article 4 of Circular No. 32/2013/TT-NHNN; clause 2, Article 95 of the Labor Code 2019).
Current legal framework
- Ordinance on Foreign Exchange 2005 (amended 2013) — Article 22 on restricting foreign exchange use within the territory of Vietnam;
- Circular No. 32/2013/TT-NHNN (guiding the restrictions on foreign exchange use) — Article 4 lists the cases where foreign exchange may be used;
- Labor Code 2019 — clause 2, Article 95: salaries stated in labor contracts and paid to employees in Vietnamese Dong; where the employee is a foreigner in Vietnam, payment may be in foreign currency.
Note: the 2010 Law on the State Bank of Vietnam remains in force (no replacing document to date) — Law No. 68/2025/QH15 on management and investment of state capital in enterprises governs state capital in enterprises and does not replace the Law on the State Bank.
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M&A, Equity Transfer and Project Transfer
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Who may an FDI enterprise pay salaries in foreign currency to?
Under item 14, Article 4 of Circular No. 32/2013/TT-NHNN, an organization (including a 100% foreign-owned enterprise) may agree and pay salaries, bonuses and allowances under labor contracts in foreign currency by transfer or in cash to:
- Non-residents; and
- Resident foreigners working for that organization itself.
For Vietnamese employees, salaries must be paid in Vietnamese Dong — not in foreign currency.
Key notes
- Agreements to pay salaries in foreign currency must be clearly stated in the labor contract;
- The enterprise must still fully perform PIT withholding and declaration obligations and pay social insurance as prescribed, regardless of the payment currency;
- Using foreign exchange outside the permitted cases may result in administrative penalties in the monetary and banking sector.
How ANT Legal can help
ANT Legal advises FDI enterprises on labor contracts with foreign employees and on compliance with foreign exchange, PIT and social insurance laws. For advice on your specific case, please contact our lawyers at 0966.475.966.
