Vietnamese companies in Russia: active DTT (10% dividends), LLC setup, VND/RUB corridors, HQS permits and compliance. 2026 practical guide.
Vietnam–Russia economic relations have deepened significantly since 2022. Vietnam is not among the "unfriendly states" designated by Russia, which means Vietnamese companies face fewer regulatory barriers than European counterparts when establishing or expanding Russian operations. The Russia-Vietnam double tax treaty remains active, providing preferential withholding tax rates across dividends, interest and royalties.
The Convention between Russia and Vietnam on the Avoidance of Double Taxation was signed in 1993 and remains fully in force. It was not suspended in 2022 — Vietnam's status as a non-unfriendly state places it outside the geopolitical pressure that led to suspensions with Western countries.
To access treaty rates, the Vietnamese recipient must be the beneficial owner of the income and must provide a certificate of tax residence from the Vietnamese tax authority. The certificate must be obtained for each tax period.
Vietnamese companies entering Russia have three primary structural options:
A Russian subsidiary provides full operational capacity — employment, contracting, property, banking. Registration takes 3–5 business days. No government commission approval is required for Vietnamese participants. Minimum charter capital is RUB 10,000, though banks typically require higher levels for account opening purposes.
Suitable for market research, liaison and promotional activities. Cannot conduct commercial operations or generate revenue directly. Accreditation with the Chamber of Commerce takes 4–6 weeks. Used as a first-step presence before committing to full subsidiary establishment.
A branch of the Vietnamese parent — not a separate legal entity. Subject to Russian tax on Russian-source income. Branch registration requires accreditation and is more complex than LLC establishment for non-regulated industries.
Vietnam and Russia do not have direct VND/RUB clearing infrastructure comparable to the CNY/RUB corridor. Payments between Vietnamese and Russian entities typically route through:
USD intermediary: Where the Vietnamese bank can process USD payments to a non-sanctioned Russian bank. Subject to US secondary sanctions risk analysis
Third-currency corridor: Through UAE dirham or Singapore dollar accounts — adds conversion costs but avoids USD/EUR correspondent bank issues
Direct VND settlement: Limited capacity — a small number of Russian banks have begun developing VND capability for trade finance purposes
Vietnamese companies with significant Russian trade volumes should engage with their Vietnamese bank's international trade finance team and the Vietnamese-Russian joint ventures that have established working payment channels.
A Vietnamese-owned Russian LLC is subject to the standard Russian tax framework:
Corporate income tax: 25% on taxable profit (from 2025)
VAT: 20% standard rate on Russian sales. Import VAT on goods brought into Russia
Payroll taxes: 30% social contributions below the unified base; 15.1% above. NDFL at 13–15% for resident employees
Currency control: Export proceeds must be repatriated; intercompany transactions with the Vietnamese parent require contract registration above RUB 6 million
Vietnamese specialists and executives can enter Russia on HQS (Highly Qualified Specialist) work permits if their salary meets the threshold (RUB 167,000 per month in 2026 for most sectors). HQS status provides:
13% NDFL rate regardless of residency status
Exemption from most social contribution obligations
Multi-entry work visa valid for 3 years
Right to bring family members on dependent visas
Vietnamese nationals do not require a quota under the standard work permit regime — unlike citizens of some other countries. This simplifies staffing for Vietnamese companies operating in Russia.
Practical support for international business in Russia.