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Investment2026-04-10 · 4 min read

Vietnam's 'China+1' Surge: Using Singapore as a Financial HQ for Manufacturing

Vietnam is the clear winner of the 'China+1' shift, but the smart money isn't going in directly. Here is how investors use Singapore SPVs to manage tax, regulation, and supply chain risks for 2026.

NL

Nicholas

CEO & Founder

The Strategic Reality of the 'China+1' Shift

Global manufacturing supply chains aren't just shifting; they are being rebuilt from the ground up. We've seen Vietnam emerge as the primary destination for the 'China+1' strategy, but the way companies enter the market has changed. Instead of direct capital injection, we are seeing a triangulated approach where Singapore serves as the legal and financial holding jurisdiction for Vietnamese operations.

Geopolitical de-risking is the main driver here. Chinese manufacturers in high-tariff sectors, specifically solar players like Jinko Solar and Trina Solar, have set up massive operations in Vietnam to keep their access to Western markets open. It isn't just about moving a factory; it's about meeting 'Rules of Origin' under the CPTPP and EVFTA. These trade deals require actual value-adding production, not just simple assembly, to get those preferential tariffs. The economics still make sense—by 2025, average monthly wages for manufacturing in Vietnam were around $350 to $400, which is a significant saving compared to China's coastal cities.

Singapore is the natural funnel for this capital. MPI data shows Singapore remained Vietnam's top foreign investor in 2025, with registered capital hitting $12.1 billion—nearly 30% of all FDI. This isn't an accident. The expanded Singapore-Vietnam Connectivity Framework Agreement has tightened the corridor for energy, sustainability, and digital economy projects, making it the default path for regional expansion.

Local compliance and financial oversight are critical for successful Vietnam market entry.

Structuring the Move: Why the Singapore SPV Works

Setting up a Special Purpose Vehicle (SPV) in Singapore is now the standard for any serious play in Vietnam. As John Wong from KPMG points out, Singapore acts as a risk-mitigation layer, offering a stable legal environment to hold Vietnamese assets.

Speed is a factor. You can get an ACRA incorporation done in 1 to 3 days. In contrast, getting your Investment Registration Certificate (IRC) and Enterprise Registration Certificate (ERC) in Vietnam can take anywhere from 30 to 90 days. By setting up the Singapore holding company first, you can pool capital and secure your IP while the Vietnamese licensing moves through the bureaucracy. For institutional players, the Variable Capital Company (VCC) framework provides a flexible way to handle capital reduction and dividends.

The tax angle is equally compelling. Under the Singapore-Vietnam Double Taxation Agreement (DTA), withholding tax on dividends drops to 5% or 10%. On top of that, Section 13(8) of the Singapore Income Tax Act means foreign-sourced dividends sent back to Singapore are usually exempt from our 17% corporate tax. Since Vietnam’s standard CIT of 20% is higher than the 15% threshold required for the exemption, the math works out in the investor's favor.

A visual breakdown of how investors use a Singapore Special Purpose Vehicle to funnel capital and manage intellectual property for Vietnamese manufacturing operations.

The Singapore-Vietnam SPV Structure

Industrial Zones and the Regulatory Ground Game

The Vietnam-Singapore Industrial Park (VSIP) network is the backbone of this trade corridor. There are now 18 VSIP projects running or approved across the country, housing over 800 companies. Decree 35/2022/ND-CP has been a game-changer for these parks, offering 'one-stop-shop' administrative services that actually work for environmental and construction permits.

Vietnam’s Law on Investment 2020 allows 100% foreign ownership in most manufacturing, but you still need to check the 'negative list' in Decree 31/2021/ND-CP for any restricted sectors. We’ve seen a massive push toward green manufacturing, driven by the Power Development Plan 8 (PDP8). Singaporean banks like UOB, DBS, and OCBC have stepped up their advisory game to match this; UOB alone has helped over 450 companies move into Vietnam as of 2025.

Special Economic Zones offer the infrastructure necessary for high-scale manufacturing operations.

Tax Incentives and the Global Minimum Tax Reality

Vietnam’s '4-9-15' tax incentive—4 years of exemption, 9 years of 50% reduction, and a 10% rate for 15 years—is still a great deal for SMEs. But for the big multinationals, the rules changed on January 1, 2024. The 15% Global Minimum Tax (GMT) now applies to any MNE with revenues over €750 million.

To keep the country attractive, the Vietnamese government launched an 'Investment Support Fund' in 2025. This fund offers direct cash support for R&D and green infrastructure to balance out the GMT’s impact. CFOs need to stop banking on old-school tax holidays and start modeling ROI based on a 15% effective tax rate, with a focus on negotiating direct grants from the new fund.

Key Takeaways

  • Set up a Singapore SPV to lock in a 5-10% dividend withholding rate and utilize Section 13(8) for tax-exempt repatriation.
  • Stick to the VSIP ecosystem (18 locations) to take advantage of Decree 35's faster administrative processing and better-quality infrastructure.
  • If your revenue exceeds €750M, stop relying on tax holidays and start negotiating for direct R&D and infrastructure grants via the Investment Support Fund.

References & Sources

  1. Ministry of Planning and Investment (MPI) Vietnam — www.mpi.gov.vn (accessed 2026-04-20)
  2. PwC Vietnam — pwc.com (accessed 2026-04-20)
  3. Sembcorp / VSIP Group — www.sembcorp.com (accessed 2026-04-20)

All information has been verified against the original sources. NovaLink Advisory makes every effort to ensure accuracy but recommends consulting official sources for the latest updates.

In This Article

  • 1. The Strategic Reality of the 'China+1' Shift
  • 2. Structuring the Move: Why the Singapore SPV Works
  • 3. Industrial Zones and the Regulatory Ground Game
  • 4. Tax Incentives and the Global Minimum Tax Reality

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