Does Vietnam have CFC rules that tax my US LLC's undistributed profits?

No — Vietnam doesn't operate a separate CFC attribution regime for individuals. Instead, resident individuals are taxed directly on worldwide income, including income received from a foreign LLC, under the standard personal income tax framework.

What rate applies to income I receive from my US LLC?

It depends on how the income is classified — business income is often taxed at 1-5% of revenue depending on activity type, while capital-investment-style income (like dividends) is typically around 5%. Confirm the correct category with a Vietnamese tax advisor given your specific situation.

Am I affected by Vietnam's tax rules if I'm not a Vietnamese tax resident?

Generally not for foreign-sourced income — non-residents are only taxed on Vietnam-sourced income, which would typically exclude income from a US LLC serving clients outside Vietnam.

What do I write for my mã số thuế on the EIN application?

Nothing — Line 7b asks for a US SSN, ITIN, or EIN, none of which apply to a Vietnamese individual. Write "Foreign" or "N/A" instead.

How long does the EIN phone application take from Vietnam?

Budget 45-60 minutes for the full call including hold time. Most applicants receive their EIN verbally before the call ends.

Reviewed & Updated September 2026

EIN for Vietnamese LLC Owners: Complete 2026 Application Guide

How Vietnamese founders get a US tax ID, and why Vietnam taxes your LLC's income directly rather than through CFC-style attribution

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Capitalizing a foreign company i… · Transfer method

Quick Summary

Country: Vietnam
Transfer method: Capitalizing a foreign company is treated as a commercial outbound investment under Decree 103/2026/NĐ-CP, requiring SBV foreign exchange registration and funding through an Offshore Investment Capital Account (OICA) — separate from Vietnam's simpler personal foreign-exchange allowance.

If your CP 575 gets lost

The IRS mails a CP 575 confirmation letter a few weeks after your call. If misplaced, the IRS won't issue a replacement, but calling the same EIN line gets you a 147C verification letter that serves the identical purpose for any bank or processor.

Fax and mail if you can't call

Fax reaches 855-215-1627 (from the US) or 304-707-9471 (from outside); mail routes through the Cincinnati service center. Both now typically run 4-6 weeks. Given the roughly 11-12 hour time difference from Vietnam to US Eastern, calling right as the line opens (early evening in Vietnam) tends to mean shorter waits.

What an EIN unlocks for your LLC

An EIN (Employer Identification Number) is the nine-digit federal tax ID the IRS assigns to your US LLC. Without it, no US bank will open a business account, no payment processor will verify your business, and no annual return can be filed under the LLC's name. It's unrelated to your Vietnamese mã số thuế cá nhân — it identifies the company, not you.

The phone application from Vietnam

Call the IRS International EIN line at 267-941-1099, open 6am-11pm US Eastern Time. This line accepts calls from Vietnam without issue — it exists precisely for foreign applicants without a US SSN or ITIN. Budget 45-60 minutes for the full call including hold time. You'll confirm your entity's legal name, formation state and date, a short business purpose, and your name and Vietnamese address as the responsible party, receiving your EIN verbally before the call ends.

Which category your LLC's income falls into

Vietnam's personal income tax law distinguishes between several income types with different rates — business income (typically 1-5% depending on the activity, applied to revenue rather than net profit for many categories), income from capital investment (around 5% on dividend-like distributions), and progressive employment-style rates for other categories. Which bucket your LLC's income falls into depends on how the income is structured and received, which is worth confirming with a Vietnamese tax advisor given the very different effective rates involved.

Residency status determines your entire exposure

Vietnam taxes worldwide income only for individuals who meet its residency test — 183 days of presence in a 12-month period, or maintaining a registered permanent residence or qualifying leased accommodation in Vietnam. If you don't meet either test, Vietnam generally only taxes Vietnam-sourced income, which would typically exclude income from a US LLC serving non-Vietnamese clients.

Line 7b: what to write instead of your mã số thuế

Form SS-4's Line 7b asks for the responsible party's SSN, ITIN, or EIN. As a Vietnamese applicant, you write "Foreign" or "N/A" — the standard, expected entry that doesn't delay your application.

Getting the classification right with a Vietnamese advisor

Given how new the 2026 PIT Law provisions are and how much the applicable rate depends on correctly categorizing your LLC's income (business income versus capital investment income), bring your EIN confirmation, LLC formation documents, and a clear description of how you actually receive money from the LLC to a Vietnamese tax advisor before your first filing under the new rules.

The 2026 Personal Income Tax Law and why the timing matters

Vietnam's new PIT Law (Law No. 109/2025/QH15) took effect July 1, 2026, alongside implementing Decree 253/2026/ND-CP and Circular 87/2026/TT-BTC. Critically, the provisions specifically governing business income for resident individuals apply from the 2026 tax year — meaning if you're filing for the current or a recent year, you're working under transitional rules that are still being clarified in practice. This is a year where checking with a Vietnamese accountant matters more than usual, given how recently the framework changed.

How Vietnam taxes your LLC's income: no CFC layer, just worldwide taxation

Unlike several countries in this guide, Vietnam doesn't operate a separate controlled-foreign-company regime that attributes a foreign entity's undistributed profits back to a resident owner. Instead, Vietnamese tax residents are simply taxed on worldwide income directly — meaning income you receive from your US LLC is assessed as ordinary taxable income when you receive it, under Vietnam's standard personal income tax framework, rather than through a separate CFC attribution mechanism.

The $25,000 US filing obligation, separate from your Vietnamese tax position

Regardless of how your LLC's income is classified under Vietnamese law, US rules require an annual Form 5472 alongside a pro forma Form 1120 for any foreign-owned single-member LLC, generally due April 15 (or October 15 with an extension). Missing this filing triggers a minimum $25,000 penalty regardless of profitability, and it requires the EIN to already be in hand.

Requirements

Requirement	Needed
US Social Security Number
ITIN
LLC formation documents
Responsible party's Vietnamese address
US registered agent address

Costs

Item	Cost
EIN Priority (bundled with Global Launch formation)	$99
EIN Follow-up (LLC already formed)	$129
DIY phone application	$0 (your time only)

Who Should Choose

DIY phone application

Free, and manageable with a 45-60 minute international call timed around the time difference.

EasyBrise EIN Follow-up ($129)

For founders whose LLC is already formed and want the IRS call handled for them.

EasyBrise EIN Priority ($99, bundled)

For founders forming their LLC now who want the EIN done in the same workflow.

Comparison

Method	Who Can Use It	Typical Time
Phone (267-941-1099)	Any foreign responsible party	45-60 minutes
Fax	Foreign or US applicants	4-6 weeks
Mail	Foreign or US applicants	4-6 weeks
Online IRS tool	US-based SSN/ITIN holders only	Not available to most Vietnamese founders

Banking

Alternative Options
Vietnam is on Mercury's prohibited-country list, but Relay does not currently restrict Vietnam-based founders and is the realistic starting point instead.

Frequently Asked Questions

More guides for founders in Vietnam

Or browse all formation guides by country.

Reviewed by EasyBrise Research Team · Updated September 2026

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