1. Regulatory Framework for Owning and Holding Bitcoin in Vietnam (2025)
Vietnam is among the global leaders in grassroots cryptocurrency adoption. Surveys indicate that over 20% of Vietnamese consumers have owned or used crypto, topping global adoption indices in 2021 and 2022 . This widespread popularity exists despite an unclear legal status for crypto assets in the country.
Legal Status: In Vietnam, Bitcoin and other cryptocurrencies are not recognized as legal tender or lawful payment instruments. The State Bank of Vietnam (SBV) has explicitly prohibited the issuance, supply, and use of Bitcoin or similar virtual currencies as a means of payment . Since January 1, 2018, using crypto for payments can incur heavy fines (VNĐ150–200 million) and even criminal prosecution under the amended Penal Code . However, owning, buying, and selling cryptocurrency is not explicitly banned. In practice it is legal for individuals and companies to hold or trade crypto as an asset, but this activity operates in a “grey area” due to the lack of dedicated regulation . Crypto is not officially recognized as money or as a commodity under current law, meaning participants have no clear legal protections . Vietnamese courts have even ruled that cryptocurrencies do not meet the definition of a lawful asset or goods, which has made it difficult for authorities to tax or regulate them under existing laws .
Evolving Regulatory Framework: The Vietnamese government is actively working on a legal framework to address this ambiguity. In early 2024, the Prime Minister issued directives requiring a draft legal framework for digital assets by May 2025, tasked to the Ministry of Finance and State Bank . The aim is to decide whether to regulate or prohibit crypto activities and to implement measures against risks like money laundering . Several initiatives are underway, including a Draft Law on Digital Technology Industry (DTI) which, for the first time, introduces definitions for “digital assets” and would likely encompass cryptocurrencies . Another proposal is to launch a pilot program for crypto asset markets via a regulated sandbox: a draft Resolution envisions establishing a financial center (potentially by 2026) that could license and oversee crypto exchanges and fintech activities in a controlled environment . The overall policy direction is to balance innovation with stability – Vietnam’s Politburo and government Resolutions in late 2024 and early 2025 signal openness to blockchain and digital assets, but under strict regulatory supervision . In summary, as of 2025 there is no comprehensive crypto law in force; owning Bitcoin is tolerated, but companies must navigate an uncertain environment pending the rollout of official regulations in late 2025 or beyond .
2. Legal Structure Options for a Bitcoin-Holding Company
Business Entity Types: Vietnam allows several business structures, of which the most suitable for a corporate treasury holding Bitcoin would be a Limited Liability Company (LLC) or a Joint Stock Company (JSC). An LLC (công ty trách nhiệm hữu hạn) is often preferred for its simplicity and flexibility – it can be established with a single owner or multiple members (up to 50) and offers limited liability protection up to the capital contributed. A multi-member LLC cannot issue shares to the public and has a member cap, but it is easier to set up and subject to fewer governance requirements than a JSC . A JSC (công ty cổ phần) is a share-issuing company that requires at least three shareholders and can have unlimited shareholders; it is the structure required if the company ever plans to list on a stock exchange or mobilize capital from the public. JSCs have more complex governance (e.g. a Board of Directors, shareholder meetings) but also greater fundraising flexibility via share issuance.
Domestic vs. Foreign Ownership: The legal procedures differ slightly if the company is 100% locally owned versus having foreign investors. A locally owned LLC/JSC can be registered relatively quickly (a few weeks) by filing the enterprise registration with the business registration authority. If foreign investors are involved, an Investment Registration Certificate may be required first, and certain business lines might need approval. Notably, “cryptocurrency trading” or related financial services are not on the list of recognized business lines in Vietnam yet (since crypto is not officially recognized). To establish a company whose main activity is holding or investing in Bitcoin, one would typically register it under a broad business category (such as investment consultancy, financial consulting, or trading in permitted assets) that does not violate any prohibitions. In practice, many Vietnam-based businesses that engage with crypto do so under general IT, software, or financial consulting licenses, since there is no specific license for crypto holding. No special license is currently required simply to hold cryptocurrency as part of corporate treasury, as long as the company is not providing crypto exchange services or token issuance (which would be illegal under current rules). The company’s charter should be drafted broadly enough to allow holding and investing in assets with its surplus funds. It is advisable to consult legal counsel to choose appropriate business lines and ensure the company’s purpose (e.g. as a financial investment vehicle or as an operating business with a Bitcoin reserve) is compliant with Vietnam’s Enterprise Law and Investment Law.
Corporate Governance Considerations: When structuring the company, it’s important to put in place governance for managing the Bitcoin treasury. Regardless of LLC or JSC, the company should establish internal rules for how decisions to acquire or sell Bitcoin are made (e.g. Board resolution or owners’ approval for large transactions) and how the private keys or access to crypto wallets will be controlled (perhaps requiring multiple signatories, see section 4 on custody). These governance measures are not mandated by law but are best practices given the unique nature of crypto assets. In summary, most entrepreneurs opt for an LLC for a closely-held venture due to simplicity, whereas a JSC might be chosen if the company expects to raise capital from many shareholders or go public in the future. In either case, at incorporation the initial capital contributions must be in traditional currency or tangible assets – Vietnamese authorities will not recognize a direct contribution of Bitcoin as charter capital. The company can later convert some of its capital into Bitcoin after establishment.
3. Compliance with Vietnamese Financial, Tax, and Cryptocurrency Laws
Establishing a Bitcoin-holding company in Vietnam requires careful compliance with several layers of regulation:
• Payment and Currency Regulations: As noted, using Bitcoin for payment is illegal in Vietnam . A company must not conduct any business transactions in Bitcoin domestically, such as paying suppliers, salaries, or rent in crypto – all such payments must be in Vietnamese đồng (VND) or other legal means. The corporate treasury Bitcoin should be treated purely as an investment asset, not as operational currency. The State Bank of Vietnam has directed banks and financial institutions to monitor and prevent illegal crypto-related payments . Therefore, the company should also avoid advertising or implying that it accepts crypto from customers for its products/services, as that could trigger regulatory penalties.
• Anti-Money Laundering (AML) and Reporting: Vietnam’s AML laws (e.g. Law on Prevention of Money Laundering) do not yet specifically list cryptocurrencies, but any large financial transactions will draw scrutiny. If the company moves funds to purchase Bitcoin (especially via international transfers), it should keep detailed records to prove the source and destination of funds in case banks or authorities inquire. Regulators are concerned about crypto being used for illicit transfers, so staying transparent and documenting transactions is important. Once Vietnam implements a crypto framework (expected by 2025), companies dealing with digital assets may be subject to licensing and KYC/AML requirements similar to securities or payment businesses . For now, a company holding Bitcoin internally does not require a special license, but it should still self-impose compliance standards, such as only using reputable exchanges that follow KYC, and internally vetting any counterparties in large OTC trades.
• Foreign Exchange Regulations: Vietnam maintains capital controls on outbound money flows. Purchasing Bitcoin on international exchanges could be considered an offshore investment or payment. There is currently no explicit rule on this, but companies must be cautious. For instance, wiring funds from a Vietnamese bank to a foreign crypto exchange may be flagged, since there is no legally recognized import of “cryptocurrency” to justify the transfer. Ideally, if a company needs to send money abroad for crypto purchase, it should consult with a bank or legal advisor on how to categorize the transfer (e.g. as payment for software or consulting, if legitimately applicable) to stay within foreign exchange rules. The lack of clear guidelines means there is a risk of violating foreign exchange regulations if large sums are moved offshore solely to buy crypto. Many Vietnamese investors currently bypass this by using peer-to-peer platforms (which keep VND flows domestic) – the company might consider a similar approach to avoid unauthorized capital outflow (see section 5 on on-ramps). Also, any incoming funds from crypto (if the company liquidates some Bitcoin for foreign currency and tries to bring it back) should be handled carefully to ensure the proper declaration of the source of funds.
• Tax Compliance: Until specific crypto tax rules are issued, Vietnamese companies are generally subject to 20% Corporate Income Tax (CIT) on any taxable profits, regardless of source. Even though the legal status of crypto is unclear, a prudent company should report and pay CIT on realized gains from Bitcoin sales or investments. In practice, some Vietnamese crypto traders have argued that crypto gains are not taxable due to lack of legal recognition (and courts have at times sided with this view) . However, the government’s stance is moving towards treating crypto-related income like any other income for tax purposes . To stay compliant, a company should maintain records of its Bitcoin purchase costs and sale proceeds in VND and be prepared to calculate gains or losses when Bitcoin is sold for fiat. It should declare those gains in its financial statements and tax filings under other income or investment income. Likewise, if the company incurs a loss on crypto trading, that could potentially be used to offset other profits (subject to Vietnamese tax rules on loss carryforward). Personal Income Tax (PIT) would apply only if individuals (e.g. employees or shareholders) receive cryptocurrency as income, but the company should avoid that scenario given the ban on crypto payments. In summary, compliance means erring on the side of treating Bitcoin activities as taxable and reportable within the existing frameworks, even if the law is silent – this approach can protect the company from future penalties once regulations are clarified.
• Accounting and Audit: From an accounting perspective, since Vietnam’s accounting standards (VAS) do not yet have crypto-specific guidance, the company’s accountants should agree on a treatment for financial reporting. Many international firms treat Bitcoin as an intangible asset on the balance sheet (under IFRS guidelines) or as inventory if they actively trade it. Intangible assets are recorded at cost and subject to impairment if the value drops. Any significant Bitcoin holdings should be disclosed in the notes to the financial statements given the material risk and volatility. An external auditor in Vietnam may raise questions due to the lack of legal recognition of crypto as an asset . The company should be ready to provide documentation for the valuation of Bitcoin and to explain its accounting policy. It’s wise to align with whatever emerging consensus local audit firms are using for crypto (some may follow IFRS interpretations, treating crypto as intangible or as a financial investment). Ensuring the accounts are transparent will keep the company in good standing with authorities and investors.
In sum, compliance in Vietnam today means operating within existing general laws: do not use Bitcoin in any way that violates currency and payment laws, maintain rigorous records and transparency, and proactively meet tax obligations on crypto-derived profits. Given the fast-evolving regulatory environment, the company should stay updated on new decrees or laws (for example, if Vietnam legalizes and licenses crypto exchanges in 2025–2026, the company might have to comply with new reporting or custody rules at that time).
4. Options for Acquiring, Storing, and Securing Bitcoin (Custody Solutions)
Once the company is established and funded (with VND or foreign currency capital), it will need to acquire Bitcoin and secure it. This process has unique considerations in Vietnam’s context:
Acquiring Bitcoin: In the absence of local licensed crypto exchanges, companies in Vietnam typically have a few avenues to acquire Bitcoin:
• Peer-to-Peer (P2P) Marketplaces: Platforms like Binance P2P, Remitano, or local crypto communities allow buying Bitcoin directly from other holders using bank transfers. The company could identify reputable OTC (over-the-counter) sellers – essentially buying BTC from an individual or broker by transferring VND from the company’s bank account and receiving Bitcoin in the company’s wallet. P2P trades can be fast and keep the funds largely onshore (VND stays within Vietnam’s banking system). However, counterparty risk is a concern – the company must ensure it deals with trustworthy sellers to avoid fraud. It should also break up large acquisitions into smaller trades to not alarm banks (large unusual transfers might be flagged).
• International Crypto Exchanges: The company can register an account on major exchanges (such as Binance, Coinbase, Kraken, etc.), though these are not regulated or officially approved in Vietnam. Using an exchange, the company could convert fiat to crypto. Since Vietnamese đồng (VND) is typically not directly supported, the company might first convert VND to USD (or USDT stablecoin) and then buy Bitcoin. This may require an intermediary step: for example, transfer VND to an exchange-friendly currency or use a third-party payment channel. Another approach is using a Singapore or Hong Kong-based exchange, given the proximity – some exchanges in those financial centers might welcome Vietnamese corporate clients (subject to their KYC checks). The challenge will be funding the exchange account: an international wire transfer from the company’s bank to the exchange’s bank is one method (but as noted, Vietnamese banks might block or question it). Alternatively, some exchanges or brokers can facilitate purchase via stablecoins or through affiliated OTC desks. If using an exchange, the company should choose one with a strong reputation for security and compliance, as recourse is limited if something goes wrong.
• Custodial OTC Brokers: There are global firms (and some regional) that offer OTC trading with custody. For instance, a company could engage a broker like Amber Group, OSL, or a global bank’s crypto desk (if available) to purchase a large amount of BTC at a negotiated price. These brokers often handle the trade and can deposit the Bitcoin into a provided custodial wallet for the client. The advantage is professional service and possibly better liquidity for large orders. The downside is the need for an offshore account or entity in some cases, and these services usually require thorough compliance checks and higher fees.
• Mining or Earning BTC: Although not the typical route for treasury, a company could also earn Bitcoin through activities like mining or accepting BTC from foreign partners (if the company has overseas dealings). Mining in Vietnam is not outright banned for individuals, but for a company it would involve importing mining equipment and significant energy use, and it’s generally beyond the scope of treasury strategy (plus regulatory risk if the government restricts mining). Accepting BTC from foreign clients for payment is legally sensitive (since technically receiving payment in crypto is not recognized), so the safer approach is to only acquire BTC through investment transactions, not by selling products in exchange for BTC.
Storing and Securing Bitcoin: After acquisition, secure storage (custody) is absolutely critical, as cryptocurrencies are digital bearer assets (whoever holds the private keys controls the funds). The company has a few options for custody:
• Self-Custody (Cold Storage): The company can hold the Bitcoin itself by managing its own wallets. Best practice is to use cold storage – keeping the private keys offline. This often involves hardware wallets (like a Ledger or Trezor device) or even a completely offline computer storing the keys. The device or key backups should be stored in secure physical locations (e.g. a safe or bank deposit box). The company should use a multi-signature wallet setup if possible: for example, require 2-of-3 or 3-of-5 keys to move any funds. This way, no single person can unilaterally transfer the Bitcoin, reducing insider risk. Keys can be distributed among trusted directors or stored in separate locations. Self-custody gives the company full control without relying on third parties, but it also means full responsibility – loss of keys or a mistake can lead to irrecoverable loss. Strong internal controls and procedures are needed (e.g. a written policy on who holds the keys, how to handle key person risk, and steps for authorizing transactions).
• Third-Party Custodian Services: Especially if the Bitcoin treasury is substantial, the company may consider professional custody solutions. Companies like BitGo, Coinbase Custody, Fireblocks, or Copper offer institutional-grade crypto custody. These services typically use advanced security (multi-sig, insurance coverage, secure vaults) and can whitelist withdrawal addresses to prevent unauthorized transfers. Some global custodians also provide insurance on crypto assets in custody up to a certain value, which can be reassuring for corporate treasurers. The challenge here is that Vietnam does not yet have any licensed crypto custodians domestically. So the company would likely engage a custodian overseas (e.g., in the U.S., Europe, or Singapore). This introduces legal considerations – the contract would be under foreign law and any disputes would be handled abroad. Nonetheless, using a reputable custodian can significantly reduce technological risk. If choosing this route, ensure the custodian is regulated in a credible jurisdiction and inquire about their compliance stance (they may ask the company to certify that the crypto holding is legal and not tied to illicit activity).
• Bank Custody (Future Potential): At present, Vietnamese banks are not offering crypto custody (since crypto is not legally recognized). In some countries, banks have begun exploring holding crypto for clients. In Vietnam, this might become possible in the future if the regulatory sandbox mentioned earlier leads to banks or licensed financial institutions being allowed to deal with digital assets. If that happens (likely only after 2025/26 when laws change), a company could eventually keep its Bitcoin with a domestic bank or licensed vault for safekeeping. For now, this option is not available.
Security Best Practices: Whichever custody option is chosen, the company should implement best practices:
• Keep a minimal amount of Bitcoin in “hot” (online) wallets – just enough for any imminent transactions – and keep the bulk in cold storage.
• Use strong encryption and multiple backups for any seed phrases or private keys. Backups should be stored securely in at least two separate geographic locations (to mitigate loss from fire, flood, etc.).
• Limit the number of employees with knowledge of or access to the keys. Ideally, keys are held by senior trusted personnel (e.g. the CEO, CFO, or a board member) and perhaps an external trusted party (like a lawyer or custodian) as part of the multi-signature scheme.
• Establish clear procedures for authorizing transfers out of the treasury. For example, require dual approval – one person initiates a transaction, another person confirms it on a separate device.
• Periodically audit the wallet (ensure the expected amount of BTC is still there and keys are functional) and also audit compliance with the procedure (especially when personnel changes occur).
In summary, acquiring Bitcoin in Vietnam as a company often involves creative workarounds (P2P trades or foreign platforms) due to regulatory constraints, and storing it demands rigorous security protocols. The company should weigh the convenience vs. security trade-off: self-custody offers control but demands discipline, while third-party custody provides convenience and safety nets but entails trust and legal overhead. Many companies opt for a hybrid (e.g. self-custody for a portion and custodial services for another portion as backup or for active trading liquidity).
5. Banking and Fiat On-Ramp/Off-Ramp Challenges and Opportunities in Vietnam
Banking Challenges: One of the most significant hurdles for a Vietnamese company holding Bitcoin is interacting with the traditional banking system for conversion between fiat and crypto. Currently, Vietnamese banks do not offer crypto exchange services and are generally wary of any crypto-related transactions. The SBV has instructed banks to closely monitor and prevent cryptocurrency transactions that might be used for illegal payments . In practice, this means if a company tries to send a large wire transfer to a known cryptocurrency exchange or receives funds with crypto-related references, the bank may freeze or scrutinize the transaction. There are anecdotal reports of banks calling in customers for questioning if they suspect crypto trading, or outright blocking credit card or bank transfers to foreign exchanges. As a result, accessing fiat on-ramps (converting VND to BTC) and off-ramps (BTC back to VND) is cumbersome:
• Converting corporate VND funds into Bitcoin often cannot be done via a simple bank order or local exchange, but rather through the P2P methods described earlier. This can be slow and capacity-limited (individual traders might only handle so much).
• Similarly, if the company wants to cash out some Bitcoin to cover expenses in VND, it cannot directly deposit BTC into a bank account. It would have to sell the BTC peer-to-peer to someone who will transfer VND to the company’s account. Large incoming transfers without a clear invoice or contract might raise questions from the bank’s compliance department (the company might need to explain it as something like a repayment or sale of an asset, which is tricky given crypto’s undefined status).
Another challenge is currency exchange control: Vietnam’s regulations require documentation for inbound and outbound fund transfers. If a company did manage to use an international exchange, say it wired USD to Coinbase and later received USD back after selling Bitcoin, the company would need to justify that flow. Without an official framework, it’s not obvious under what transaction category those funds fall. There’s a risk that authorities could deem unapproved crypto-related transfers as violating foreign exchange rules or even anti-money-laundering rules.
Opportunities and Workarounds: Despite these challenges, Vietnamese crypto users have been very resourceful, and some of those methods can be applied by companies:
• Stablecoin On-Ramps: Instead of directly buying BTC with VND, the company might buy a stablecoin like USDT or USDC via local P2P markets (since stablecoins are frequently traded for VND). Once the company holds stablecoins (which closely represent USD), it can easily trade those for Bitcoin on any exchange or DEX (decentralized exchange). Stablecoins thus act as a bridge to the crypto world. Many Vietnamese traders do this to avoid direct bank-to-exchange links. The risk here is that buying stablecoins P2P still involves counterparty trust and potential regulatory scrutiny if identified, but it’s a widely used method.
• Offshore Banking: If the founders or parent company have access to a bank account in a more crypto-friendly jurisdiction (for example, Singapore, Switzerland, or Hong Kong), they could consider routing investment funds through that account. An offshore entity could handle the conversion from fiat to crypto, and then transfer the Bitcoin to the Vietnam entity’s wallet. This effectively shifts the on-ramp/off-ramp activity outside of Vietnam’s banking system. However, this approach might require an offshore corporate structure and introduces complexity in accounting and intra-group transfers (and it should be done with advice to ensure it doesn’t violate any Vietnamese laws on related-party transactions or capital contributions).
• Future Regulatory Changes: Opportunities may significantly improve if Vietnam implements the proposed regulatory sandbox and crypto exchange pilot. The government’s draft plans suggest that by July 2026, Vietnam could see transactions on a licensed digital asset exchange as part of a pilot in a regulated financial center . If that happens, companies might eventually have domestic, legally sanctioned on-ramps/off-ramps where they can convert between VND and Bitcoin under the oversight of authorities. Additionally, Vietnam’s consideration of a central bank digital currency (CBDC) or other blockchain initiatives could modernize the banking system’s approach to digital assets . For now, these remain plans – the company should stay abreast of announcements by SBV or MoF for any pilot programs it could join.
Banking Relationships: The company should proactively maintain good communication with its banks. It may be wise to inform the bank (at least in general terms) that the company may engage in overseas investments or digital asset investments, without immediately triggering alarm. Ensuring the company’s other activities and accounts are in good standing will help if ever a large transaction is flagged – a transparent history and proper documentation can sometimes convince a bank to process a one-off transfer. Some companies also diversify banking relationships (having accounts with multiple banks) so that if one bank is particularly strict on crypto, another might be more lenient. Nonetheless, all banks are under the same regulations from SBV, so none can officially endorse crypto transactions yet.
Payment Processing and Vendors: Another aspect is dealing with operational finances. Since the company cannot pay Vietnamese vendors or employees in BTC, it will need to convert BTC to VND whenever it wants to use those funds. This conversion risk (timing and exchange rate risk) must be managed. The company might choose to only allocate excess capital to Bitcoin and keep sufficient cash in VND for short-term obligations, to minimize frequent conversions. If the company has foreign vendors or investors, in theory they could agree to settle in crypto, but doing so involves legal risk on the Vietnam side. Until laws change, it’s safer for the Vietnam entity to conduct all day-to-day cash flows in fiat and treat Bitcoin purely as a reserve asset.
In summary, Vietnam’s banking system currently poses significant friction for crypto treasury operations. Companies have to rely on semi-informal methods to move between fiat and crypto, which entails counterparty risk and compliance risk. The situation may improve with upcoming legal frameworks – possibly enabling regulated exchanges or fintech solutions – but until then, any company pursuing a Bitcoin treasury strategy in Vietnam must plan around these on/off-ramp difficulties. It’s advisable to budget extra time and costs for converting funds and to have contingency plans (for example, having a trusted OTC broker or a foreign account ready) to ensure liquidity when needed.
6. Tax Treatment of Bitcoin on the Balance Sheet
Lack of Explicit Guidance: As of 2025, Vietnam has not issued specific tax regulations for cryptocurrencies, leading to uncertainty in how Bitcoin holdings should be taxed and reported. Cryptocurrency is not formally recognized as an asset or foreign currency under Vietnamese law . This means there is no direct classification in the tax code for profits or losses stemming from crypto. The tax authorities have attempted in some cases to tax crypto trading profits under existing frameworks, but there have been legal challenges. For instance, a Vietnamese court ruled that since crypto is not recognized as property or goods, certain attempted tax assessments on crypto transactions were not enforceable . Nonetheless, this judicial stance could be temporary – the government is actively looking to bring crypto into the tax net with new laws. A forthcoming legal framework is expected to clarify tax obligations for digital assets by late 2025, potentially defining crypto as a taxable asset class .
Corporate Income Tax (CIT): In the absence of bespoke rules, the conservative approach is to treat realized gains from Bitcoin just like any other investment income. Vietnam’s corporate income tax rate is 20%. If the company sells Bitcoin at a profit (i.e. the sale price in VND exceeds the book value/cost of the Bitcoin holding), that profit would be added to the company’s taxable income for the year. Likewise, if the company incurs a loss on selling Bitcoin (sell price below cost), that could be considered a deductible loss, offsetting other income (subject to Vietnam’s rules on carrying losses forward to future tax years). Notably, if the company simply holds Bitcoin and its value rises, unrealized gains are not taxed – tax would only be due when you convert the Bitcoin into fiat or possibly trade it for another asset and realize a gain. This is aligned with general principles: Vietnam taxes profits when realized, not on mark-to-market asset fluctuations (especially since under current accounting rules you wouldn’t mark to market, see below). There have been discussions that Vietnam might impose a specific capital gains tax on crypto transactions for individuals and businesses at around 20% , essentially mirroring the CIT rate for companies. Until laws explicitly say so, 20% CIT on net profits is the de facto rule.
Value Added Tax (VAT): Vietnam imposes VAT on goods and services, but how does that apply to Bitcoin? Since Bitcoin is not a recognized good or service and not legal tender, VAT is generally not applied to buying or selling Bitcoin itself. If the company were in the business of providing crypto-related services (like operating an exchange or broker service), then any service fees or commissions might attract VAT (Vietnam’s standard VAT rate is 10%). In fact, proposed guidelines suggest a 10% VAT on the service fees of crypto exchanges, but not on crypto asset value directly . For a company simply holding Bitcoin on its balance sheet, there is no VAT event unless it is selling goods/services. If the company ever uses an overseas service (like a foreign exchange or custodian that charges fees), those fees wouldn’t be Vietnamese VAT, though theoretically import of services can trigger VAT via a reverse charge mechanism (this likely won’t be enforced for crypto services given the gray area, but it’s something to keep in mind).
Accounting Treatment (Balance Sheet): Accounting for Bitcoin in Vietnam must consider both VAS (Vietnamese Accounting Standards) and potentially IFRS (if the company opts or is required to report under international standards). Since Vietnam hasn’t updated VAS to address crypto, companies look to international norms. Under current IFRS interpretations, cryptocurrency like Bitcoin is usually classified as an intangible asset (IAS 38) unless it’s held for sale in the ordinary course of business (in which case it could be treated as inventory under IAS 2). For a treasury holding, intangible asset classification is typical . This means:
• On initial recognition, Bitcoin is recorded at cost (the purchase price plus any directly attributable costs).
• It is not amortized (since it has an indefinite life), but it must be tested for impairment. If at any balance sheet date the market value of Bitcoin has fallen below the carrying value on the books, the company should write it down to the recoverable amount and recognize an impairment loss. For example, if the company bought BTC at $30,000 each and by year-end the price is $25,000, an impairment expense would be recorded to bring the book value down to $25,000.
• Conversely, if the price rises, no upward revaluation is recorded under the intangible asset model (unless using revaluation model which is uncommon for intangibles like crypto). The gain is only recognized when the asset is sold. This conservative accounting means the balance sheet might undervalue the Bitcoin if its price has increased substantially, and those gains won’t appear in profit until realized by a sale.
• The company’s financial statement notes should disclose the historical cost of the Bitcoin, any impairments, and perhaps the market value at the reporting date (some companies choose to disclose fair value of significant holdings for transparency, even if not recorded on the face of the balance sheet).
Under VAS, which is more rules-based, there is no official guideline, but likely auditors would analogize to IFRS. They may also consider classifying Bitcoin as a kind of “investment” on the balance sheet – possibly under “other long-term investment” – but since it’s not a security or cash, intangible is still the closest fit. The Ministry of Finance has hinted that tax and accounting standards for crypto will be addressed after the legal status is defined, potentially issuing new guidance once the law recognizes digital assets .
Tax Reporting: Even though crypto is a gray area, a company should be transparent in its tax filings. This means if it has crypto holdings, it should inform its tax office in the annual financial statements (for instance, listing Bitcoin under “other assets” or however classified). If there are realized gains or losses, those should be included in the annual corporate income tax finalization. As Dr. Truong Minh Huy Vu noted, currently “investors and businesses… don’t know how or to whom they should pay taxes” on digital assets, but once regulations come, authorities will expect compliance and may scrutinize past undeclared gains . By voluntarily complying under general tax principles now, the company reduces the risk of penalties later when rules tighten.
It’s also worth noting there is no specific wealth tax or crypto holding tax in Vietnam at this time . Simply holding Bitcoin does not incur tax until there is a taxable event (sale or exchange yielding profit). If the company were to receive Bitcoin as payment from abroad (which, again, is sensitive legally), that might be treated as revenue at the fair market value of BTC at time of receipt and thus subject to CIT as revenue – but since domestic crypto payments are banned, this scenario would only apply if, say, a foreign subsidiary paid the Vietnam company in BTC.
In summary, the tax treatment of Bitcoin on a company’s balance sheet in Vietnam is currently based on cautious interpretation of existing laws: treat crypto profits as taxable corporate income, report losses as deductible, and follow standard accounting impairment rules for asset values. The company should keep an eye on upcoming official guidelines; by 2025 a new law may explicitly impose rules like a 20% capital gains tax on crypto profits and clear accounting classification. Being prepared to adapt financial reporting when those changes arrive is part of the treasury strategy’s planning.
7. Risks and Limitations of a Bitcoin Treasury Strategy in Vietnam
Holding Bitcoin in a corporate treasury can be rewarding but comes with substantial risks and limitations, especially in Vietnam’s context:
• Regulatory Risk: The foremost risk is regulatory. Vietnam’s legal framework for crypto is in flux and could evolve in restrictive ways. There is a possibility that by mid-2025 the government could decide on stricter controls or even an outright ban on corporate crypto holdings (though a full ban seems less likely given the trend toward regulation). New regulations might require disclosures of crypto holdings, impose licensing for companies dealing in crypto, or subject the company to compliance audits. The company must be ready to quickly adapt if, for example, a law mandates that all crypto assets be registered with the central bank or that certain types of entities (like financial institutions) cannot hold crypto. In the worst case, if authorities later viewed corporate crypto holdings as illegal, the company could be forced to divest its Bitcoin at short notice or face legal consequences. Monitoring policy developments is crucial to mitigate this risk.
• Market Volatility: Bitcoin’s price volatility is well-known. A sharp decline in Bitcoin’s value could significantly affect the company’s financial health. Unlike traditional reserves (cash or government bonds), Bitcoin can swing 20-30% in a single month. This volatility could impact the company’s balance sheet (through impairment losses) and could even jeopardize its solvency if the Bitcoin position is large relative to the company’s equity. For example, if a company put a large portion of its treasury into BTC and the price crashed, the company might struggle to raise fiat cash when needed or could breach debt covenants due to asset devaluations. To manage this, the company should only allocate an amount it can afford to have locked up long-term and potentially lose without threatening operations. Some companies also explore hedging strategies (like futures or options) to mitigate downside risk, but those instruments introduce complexity and, in Vietnam, access to crypto derivatives would be limited to offshore markets.
• Security and Custodial Risk: Holding Bitcoin safely is challenging. There is risk of theft, hacking, or loss of keys. If the company opts for self-custody and an employee mishandles the private keys (for instance, falls for a phishing scam, or simply loses the hardware wallet), the Bitcoin could be irrevocably lost. If the company uses a third-party custodian, there is counterparty risk – the custodian could itself be hacked or could freeze withdrawals due to regulatory issues (as seen in some crypto platforms historically). Although reputable custodians carry insurance, recovering lost funds might be a protracted process. The company must also consider internal fraud risk: without proper multi-sig controls, a rogue insider with access to keys could siphon off coins. SBV has warned that investing in crypto carries significant risks for investors due to such security issues and market instability . Robust security protocols (as discussed in section 4) and thorough background checks on any personnel with key access are essential to mitigate these risks.
• Liquidity and Cash Flow Limitations: Using Bitcoin as a treasury asset can introduce liquidity constraints. If the company needs cash quickly (say for an urgent investment or expense), converting Bitcoin to VND might not be instant given the banking hurdles. There’s a risk that during a market downturn or a regulatory crackdown, liquidity could dry up – finding buyers for BTC at a fair price might be difficult just when the company most needs to sell. Additionally, large sales might move the market or attract unwanted attention. The company should maintain a buffer of liquid assets in fiat to cover near-term obligations, so it is not forced to liquidate Bitcoin at an inopportune time. Essentially, Bitcoin should be treated as a long-term, illiquid reserve from an operational standpoint, unless the on/off-ramp situation improves.
• Financial Reporting and Audit Risk: As mentioned, auditors in Vietnam may take a conservative view of crypto holdings. There is a risk that an auditor might issue a qualified opinion on the financial statements if they are uncomfortable with the accounting treatment or valuation of Bitcoin. This could affect the company’s relationships with banks or investors who rely on audited statements. Moreover, if the company is part of a larger corporate group or has foreign investors, differing views on how to handle crypto in reports could cause friction. Being at the bleeding edge (one of the first companies holding Bitcoin publicly in Vietnam) means facing uncertainties in reporting standards. The company should engage its auditors early to agree on an approach and ensure full disclosure to avoid compliance issues.
• Reputation and Stakeholder Perception: While Bitcoin has gained acceptance globally, in some conservative business circles it is still viewed with skepticism. In Vietnam, the government and mainstream media have often highlighted the risks of cryptocurrency – from scams to instability. A company that openly adopts a Bitcoin treasury strategy might face questions or concerns from traditional stakeholders: banks might see it as higher risk, some customers or partners might worry about the company’s focus, and investors/shareholders might be concerned about volatility and compliance. There is also the public perception risk – if the Bitcoin investment goes wrong (e.g. large losses), it could attract negative press or regulatory scrutiny (“company X gambled its funds in Bitcoin”). To mitigate this, the company should have a clear communication strategy about why it holds Bitcoin (e.g. as a hedge against inflation or devaluation, as a long-term store of value akin to digital gold). It should reassure stakeholders that this is a measured part of its treasury, not a speculative bet with critical funds.
• Legal Enforcement Risk: Given Bitcoin’s gray status, if something goes awry – for example, if the company is defrauded in a crypto transaction or if an employee misappropriates the Bitcoin – the legal remedies are uncertain. Vietnamese law enforcement might not be well-equipped to help recover crypto assets, and since crypto isn’t officially recognized, pursuing legal action (like suing for return of “property”) can be complicated. The company is somewhat on its own in protecting these assets. This also means any contracts the company enters into that involve crypto (like an OTC purchase agreement) could be tricky to enforce in Vietnamese courts. There’s an inherent risk in dealing with an asset that the legal system hasn’t fully acknowledged.
• Strategic Risk: Finally, there is the risk that the rationale for holding Bitcoin might not pan out. If the company’s strategy is predicated on Bitcoin being an inflation hedge or appreciating over time, there’s no guarantee of outcomes within the needed timeframe. If macroeconomic conditions change (for example, if inflation is tamed and interest-bearing assets become more attractive, or if a better technology emerges), Bitcoin’s appeal could wane. A company treasury must prioritize capital preservation and liquidity; if Bitcoin’s correlation with other assets or its market dynamics change unfavorably, the company might have to pivot its strategy, potentially at a loss.
In summary, while a Bitcoin treasury can offer potential upside (and indeed some see it as a way to safeguard value against currency depreciation or to signal innovation), it comes with heightened risks in Vietnam. These include regulatory uncertainty, extreme volatility, security challenges, and practical liquidity and accounting issues. A wise company will approach this strategy with robust risk management: diversify its treasury (not all eggs in the Bitcoin basket), implement strong controls, obtain legal and financial advice, and possibly use insurance or hedging where available. It’s about balancing the visionary aspect of embracing a new asset class with a sober understanding of the pitfalls in the current environment.
8. Notable Examples of Bitcoin Treasury Strategies in Vietnam and Southeast Asia
Adopting Bitcoin as a corporate treasury asset is still a novel concept in Vietnam, and there are few public examples of Vietnamese companies doing so to date, largely due to the regulatory uncertainties. Most cases of crypto holdings in Vietnam are individual investors or crypto-specific startups rather than traditional companies. No major Vietnam-based public company has officially announced Bitcoin on its balance sheet as of 2025. However, the interest in the region is growing:
• Crypto Native Companies: A number of Vietnamese-founded crypto startups (such as Sky Mavis of Axie Infinity fame, KardiaChain, Coin98, etc.) inherently hold cryptocurrencies as part of their operations. While not “treasury strategies” in the traditional sense, these companies often keep significant crypto reserves (e.g., funds raised in crypto or profits in crypto). Their example shows technical know-how in handling digital assets, but they operate in a space that’s still somewhat separate from mainstream corporates. Traditional companies are watching these developments but have mostly stayed on the sidelines until regulations clarify.
• DigiAsia (Southeast Asia): In the broader Southeast Asia region, there are a few emerging examples. DigiAsia, a fintech company focusing on Southeast Asian markets (based in Indonesia, but listed on NASDAQ), announced in 2025 a plan to allocate up to $100 million to a Bitcoin treasury reserve . This is one of the most significant Bitcoin treasury commitments by a company operating in Asia. DigiAsia’s strategy includes raising capital specifically to invest in Bitcoin as a reserve asset, signaling confidence in Bitcoin’s long-term value. They also plan to integrate crypto services into their financial platform, bridging fintech with crypto payments in the region . While DigiAsia is not a Vietnamese company, its move is notable in the regional context and may inspire similar thinking in Vietnam’s fintech sector.
• MicroStrategy and Global Examples: Regionally few companies have gone as far as DigiAsia, so Vietnamese firms often look to global examples for inspiration. The most famous case is MicroStrategy (USA), a publicly traded business intelligence company that converted a large portion of its corporate treasury into Bitcoin starting in 2020. MicroStrategy now holds over 150,000 BTC, making it the largest corporate holder . Their CEO argued this was to protect against dollar inflation and increase asset yields. Similarly, Tesla (USA) purchased $1.5 billion in Bitcoin in 2021 (though it later sold a portion) . These moves by U.S. companies legitimized the concept of holding Bitcoin as a treasury reserve. In Asia, examples include Meitu (China), a tech company that bought Bitcoin and Ether in 2021, and some blockchain-focused firms like Hive Blockchain (Canada) or Galaxy Digital (Canada) which hold crypto as part of their balance sheets . While not Southeast Asia, their cases are often studied by financial officers in Vietnam. The key takeaway is that very few non-crypto companies have done this, even globally (only around 34 public companies worldwide held significant Bitcoin by mid-2021 , though the number has grown slightly since).
• Southeast Asian Financial Institutions: A notable development is that some banks and financial institutions in the region have started dipping into crypto (mostly for service offerings rather than treasury reserves). For example, DBS Bank in Singapore launched a digital exchange and reportedly held some crypto liquidity to facilitate client trades. UnionBank in the Philippines experimented with holding a small amount of Bitcoin and offering custody for its clients. And in Thailand, Siam Commercial Bank (SCB) through its venture arm SCB 10X has invested in crypto ventures (though not necessarily holding Bitcoin on SCB’s own balance sheet). These cases show a growing acceptance in the financial sector, which could pave the way for more treasury adoption once legal frameworks are in place.
• Local Vietnamese Corporates: While no Vietnamese conglomerate or listed firm has publicly declared a Bitcoin treasury, there is anecdotal information that some privately-held companies have started to buy crypto as an investment. These are usually smaller enterprises or family offices diversifying their wealth. For example, some real estate and tech company owners have privately disclosed buying Bitcoin as a hedge against currency depreciation (the Vietnamese đồng has been relatively stable, but there’s awareness of inflation hedging). We have yet to see an official press release or financial report from a Vietnam-incorporated company stating “we hold X Bitcoin.” This is likely to remain the case until Vietnam’s legal stance is clearer; companies are understandably cautious. The first movers might be companies in the tech sector or those with foreign exposure, as they tend to be more comfortable with digital assets.
In conclusion, the Bitcoin treasury trend is at a nascent stage in Vietnam and Southeast Asia. The most prominent examples influencing Vietnamese discourse are international ones like MicroStrategy’s bold Bitcoin bet, and regionally, fintech players like DigiAsia pushing the envelope . Vietnamese companies are observing and learning from these examples. It is expected that once Vietnam establishes a clear regulatory framework (providing legal grounds to hold and account for crypto), some forward-thinking companies – perhaps in fintech, e-commerce, or export-oriented industries – will publicly adopt a Bitcoin treasury strategy to capitalize on the advantages demonstrated elsewhere (such as asset appreciation and diversification). Until then, any current corporate holders in Vietnam are likely keeping a low profile about their crypto, exercising caution in a landscape that is rapidly evolving.
Sources:
1. State Bank of Vietnam – Legal Status of Bitcoin: SBV statement on prohibition of Bitcoin as payment (Vietnam News) .
2. Cointelegraph – Overview of Crypto Regulations in Vietnam (2023) – highlights illegality of crypto as payment, legal grey area for ownership, and planned 2025 regulatory framework .
3. Tilleke & Gibbins (Law Firm) – Vietnam’s Emerging Regulatory Landscape for Cryptocurrency (2024) – details on draft laws and government resolutions aiming to regulate crypto by 2025 .
4. ASL Law – Legal Framework for Virtual Assets in Vietnam – confirms no current crypto-specific laws and the prohibition on using Bitcoin as payment .
5. AHK/Luther Law – Vietnam’s Crypto Paradox: No Legal Recognition, Unclear Tax Treatment (Apr 2025) – notes court cases denying crypto as taxable property and the absence of crypto tax regulations pending new laws .
6. AInvest News – Vietnam’s Crypto Taxes: 20% CGT on Profits, 10% VAT on Fees by 2025 – outlines expected tax approach (20% tax on crypto trading profits, no tax until profits realized) .
7. Vietnam Investment Review – Digital asset tax collection imminent (2023) – discusses challenges in taxing crypto and foreign outflow of funds; expert quotes on need for clear tax policy .
8. Blockhead – Vietnam accelerates legal framework for digital assets (Mar 2025) – news on Prime Minister’s directive and sandbox for crypto exchanges by 2026 .
9. Baker McKenzie – Financial Services Regulatory Guide: Vietnam – notes SBV warnings on virtual currencies and upcoming legal framework decision in 2025 .
10. The Asian Banker – Top Companies with Bitcoin Holdings (2021) – provides context on global corporate Bitcoin adoption (e.g. MicroStrategy, Tesla) .
11. Investing.com News – DigiAsia to raise $100M for Bitcoin reserve (2025) – example of a Southeast Asia-focused fintech adopting a Bitcoin treasury strategy .