EOR Vietnam

Segment guide · EOR Vietnam

EOR Vietnam for Japanese companies

A Japanese company can put staff on a compliant Vietnamese payroll through an employer of record, with no entity of its own on the ground. Japan's cross-border position is specific: an income-tax treaty with Vietnam has been in force since 1995, yet no social-security agreement exists — so a Japanese hire on a local contract generally pays into Vietnam's social insurance, unlike a detached Korean secondee.

Published · Last reviewed October 2026 · 11 min read · Reviewed against instruments in force

Not advice

Treat this as background for Japanese employers, not legal, tax or payroll advice. Figures are dated and sourced as of October 2026, and every cross-border posting turns on its own facts — so confirm the position with Vietnamese and Japanese advisers before you act on it.

A Japanese company can employ staff in Vietnam through an employer of record (EOR) without setting up a local entity: a Vietnam-registered company becomes the legal employer, holds the labour contract, runs payroll and statutory insurance and invoices your head office, while your managers direct the work.1 Two things make the Japan case distinct from Korea's. There is no Japan–Vietnam social-security agreement in force — intergovernmental talks only opened on 22 July 2025 — so a Japanese employee on a Vietnamese contract generally pays Vietnamese social insurance, with no detachment relief of the kind Korea has.3 But the Japan–Vietnam income-tax treaty has been in force since 1995, so relief from double income tax can be claimed — something US companies, whose treaty was never ratified, cannot do.56

How does a Japanese company hire in Vietnam through an EOR?

You do not need a Vietnamese subsidiary to put someone on a compliant local contract. Under the EOR model a Vietnam-registered entity signs the labour contract and is the legal employer under the Labour Code 2019, while your company keeps direction of the work through a service agreement.1 That entity runs the written contract, monthly payroll, the employer social, health and unemployment contributions (about 23.5% of gross salary for a Vietnamese national), personal income tax withholding, payslips, and onboarding and offboarding. If you are new to the model, begin with how an employer of record works in Vietnam. For a Japanese national you post in, the EOR also handles the work-permit dossier and the visa and temporary residence card before the person can lawfully start.

Do Japanese secondees pay Vietnamese social insurance?

Usually, yes. A foreign national who holds a work permit and a Vietnamese labour contract of twelve months or more joins compulsory social insurance and health insurance — though not unemployment insurance, which is reserved for Vietnamese citizens. The split is about 9.5% from the employee and 20.5% from the employer, roughly 30% together, against about 32% for a Vietnamese national, under the Social Insurance Law 41/2024/QH15, in force 1 July 2025.2 The 2% trade-union fee applies whatever the employee's nationality, so a Japanese hire's all-in employer on-cost is about 22.5%, against about 23.5% for a local. A narrow exemption can still apply — a qualifying intra-corporate transferee under Decree 219/2025, or someone over retirement age — so confirm each person's status rather than assume. The detail sits on our page about social insurance for foreign employees.

The missing piece is the treaty. Japan and Vietnam only opened negotiations on a bilateral social-security agreement on 22 July 2025; as of October 2026 nothing is signed, ratified or in force.3 Until one exists, a person moving between the two countries can be charged social-security contributions in both systems at once, with no way to elect one or credit the time across. Korea is the counter-example: its agreement with Vietnam has run since 1 January 2024 and lets a posted worker stay in the home system for up to 60 months, extendable by a further 36.4 A Korean parent can often detach a secondee; a Japanese parent, for now, cannot — see how the Korean case differs.

How Japan compares with Korea and the United States for an assignee to Vietnam — as of October 2026
Home country Social-security agreement with Vietnam Income-tax treaty with Vietnam What it means for your assignee
Japan None in force; talks began July 20253 In force since 19955 Generally pays Vietnamese social insurance on a local contract; can claim tax-treaty relief against double income tax.
South Korea In force since 1 Jan 2024; detachment up to 60 (+36) months4 In force A posted worker can stay in Korea's system and avoid double social insurance for a defined period.
United States None Signed 2015, never ratified by the US Senate — not in force6 Pays Vietnamese social insurance; no treaty relief — relies on the US foreign tax credit.

Is there a tax treaty between Japan and Vietnam?

Yes. The Japan–Vietnam income-tax treaty was signed on 24 October 1995 and entered into force on 31 December 1995, and it remains in force.5 It is one of the more than 80 double-taxation-avoidance agreements Vietnam has signed, most modelled on the OECD convention; each decides which country taxes a given type of income and relieves double taxation.8 For a Japanese group with people and profits on both sides, that treaty is a genuine planning tool — and precisely what a US company lacks.6

Relief is never automatic, though. Since 1 July 2026 Vietnam has applied its treaties under Circular 95/2026/TT-BTC, which replaced the long-standing Circular 205/2013. A benefit has to be claimed within a three-year window, with a tax-residency certificate and supporting evidence, and the authority can test the economic substance behind an arrangement, not just the documents, before allowing it.7 We set out the mechanics on Vietnam's double-tax-treaty network.

A long-standing Japanese investment base in Vietnam

Japanese firms are not newcomers to Vietnam, which is part of why the EOR model fits so many of them. As of 31 March 2026, Japan held about 5,760 active investment projects worth roughly US$79 billion in registered capital, ranking third among the 154 countries and territories investing in Vietnam, behind South Korea and Singapore — Ministry of Finance figures reported by The Investor.10 An EOR suits the moments around that base: a first hire or two — a country manager, an engineer, a liaison — to test the market before a subsidiary is decided, or to keep a small team running while that decision is open. A country manager is often that first hire, and also the role most likely to raise permanent-establishment questions; the role-level guide is hiring a country manager or sales rep in Vietnam. It puts someone on a compliant Vietnamese contract in days, rather than the one to three months an investment- and enterprise-registration route typically takes.

Does an EOR remove permanent-establishment risk?

Not on its own. Putting a licensed Vietnamese company in the employer's seat helps, but it does not by itself stop the Japanese parent being treated as having a taxable “permanent establishment” in Vietnam — that turns on what the worker actually does.9 If someone in Vietnam habitually negotiates or concludes contracts that bind the overseas company, the tax authority can treat them as a dependent agent and find a taxable presence, even with no office. Since July 2026 the authorities also weigh economic substance more heavily. This is fact- and treaty-specific: take Vietnamese tax advice, keep deal-making authority with the Japanese company, and hold the in-country role to support and delivery. The mechanism is set out under permanent-establishment risk in Vietnam.

How EOR Vietnam serves Japanese companies

EOR Vietnam is a Vietnam-focused employer of record with an English-language service and one point of contact, info@eorvietnam.vn. We employ your hire through a Vietnam-registered entity and take care of the labour contract, payroll in dong, the social, health and unemployment contributions, personal income tax withholding, payslips, and onboarding and offboarding — plus the work-permit, visa and residence-card dossier for any Japanese national you post in. Where the Japan–Vietnam tax treaty may reduce double taxation, we flag it and prepare payroll so you can claim relief with the right residency certificate, working with your tax adviser.

Pricing is simple and flat: US$149 per employee per month for a Vietnamese national, the same whatever the salary, seniority, role, location or headcount, and not a percentage of payroll (as of October 2026). We do not charge setup, onboarding, offboarding, contract or payslip fees, and there are no hidden fees. Japanese and other foreign nationals who need a work permit are priced separately, because the permit, visa and residence work varies case by case. We hold a refundable security deposit of two months of the employee's employment cost — gross salary plus the statutory employer contributions — for the length of the engagement, returned at the end less any unpaid amounts. Everything beyond our fee — gross salary, the employer contributions and any statutory or agreed payments — is passed through at cost. See the full figure on what an EOR costs in Vietnam and the employer-side detail on Vietnam payroll and employer costs. For the wider picture, start from the EOR Vietnam overview or the Vietnam employer guides — and when you are ready, request a costed quote.

Frequently asked questions

Can a Japanese company hire in Vietnam without a local entity?

Yes. Through an employer of record, a Vietnam-registered company signs the labour contract and acts as the legal employer, while your company directs the work under a service agreement. It handles payroll, the employer contributions (about 23.5% of gross for a local hire), tax withholding, payslips and work permits — so no Japanese subsidiary or investment registration is needed.

Is there a social security agreement between Japan and Vietnam?

Not yet. Japan and Vietnam opened talks on their first social-security agreement on 22 July 2025, but as of October 2026 nothing is signed, ratified or in force. Until one exists there is no detachment mechanism, so a person working across both countries can be charged social-insurance contributions in each system at the same time.

Do Japanese secondees pay Vietnamese social insurance?

Usually. On a work permit and a Vietnamese contract of twelve months or more, compulsory social and health insurance apply (about 9.5% from the employee, 20.5% from the employer); unemployment insurance does not. A narrow exemption — a qualifying intra-corporate transferee, or someone over retirement age — can apply, so confirm each case. With no Japan–Vietnam agreement in force, there is no way to stay solely in Japan's system.

Is there a tax treaty between Japan and Vietnam?

Yes. The Japan–Vietnam income-tax treaty was signed in October 1995 and has been in force since 31 December 1995 — one of more than 80 such treaties Vietnam has signed. It can relieve double income tax, but relief must be claimed with a tax-residency certificate under Circular 95/2026 and is not automatic. This is the clear contrast with the United States, which has no treaty in force with Vietnam.

Does hiring through an EOR create a permanent establishment in Vietnam?

It can, so it is worth planning. The EOR is the legal employer, which keeps the hire as ordinary Vietnamese employment, but the Japanese company may still face a permanent establishment if its worker here habitually closes or negotiates binding deals for it. The outcome depends on the facts and the Japan–Vietnam treaty, and economic substance has been scrutinised more closely since July 2026. The safe pattern is to leave contracting authority in Japan and take tax advice.

How much does it cost to hire in Vietnam from Japan?

For a Vietnamese national, EOR Vietnam charges a flat US$149 per employee per month on top of gross salary and the roughly 23.5% statutory employer contributions, with no setup or hidden fees (as of October 2026). Japanese nationals who need a work permit are quoted separately. The statutory on-cost and the flat fee are always shown as separate lines on the quote.

Sources

  1. Labour Code No. 45/2019/QH14 — Art. 13 relationship test and the direct-employment basis for the EOR model. Accessed 3 October 2026.
  2. Law on Social Insurance No. 41/2024/QH15 — compulsory social and health insurance for foreign employees on a 12-month-plus contract (no unemployment insurance); about 9.5% employee / 20.5% employer. In force 1 July 2025. Accessed 3 October 2026.
  3. Orbitax — Japan and Vietnam commence social-security-agreement negotiations (began 22 July 2025; not yet signed, ratified or in force). Accessed 4 October 2026.
  4. Vietnam Briefing — Vietnam–South Korea Social Security Agreement (in force 1 January 2024; home coverage up to 60 + 36 months), with KPMG GMS Flash Alert. Accessed 3 October 2026.
  5. Japan Ministry of Finance — list of tax conventions — Japan–Viet Nam income-tax convention, signed 24 October 1995, in force 31 December 1995. Accessed 4 October 2026.
  6. WNA — the US–Vietnam tax treaty is still not in force (signed 2015, never ratified by the US Senate). Accessed 3 October 2026.
  7. EY — Circular 95/2026/TT-BTC on applying Vietnam's tax treaties (from 1 July 2026; relief claimed with a residency certificate; substance test; replaces Circular 205/2013). Accessed 3 October 2026.
  8. EY Global Tax News — Vietnam's double-tax-treaty network (more than 80 signed agreements). Accessed 3 October 2026.
  9. Acclime — permanent establishment in Vietnam — the dependent-agent limb; an EOR does not by itself remove PE risk. Accessed 3 October 2026.
  10. The Investor (VAFIE) — Japanese FDI in Vietnam — about 5,760 active projects, roughly US$79 billion registered capital, third among 154 investors (behind South Korea and Singapore), Ministry of Finance data as of 31 March 2026 (dated market context). Accessed 4 October 2026.