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Points to consider when foreign workers are working at multiple locations

2025/08/18

  • Nguyen Thi Thuy Nhi

Introduction

In the pursuit of optimizing human resources, many foreign companies aim to improve efficiency in human resource utilization and reduce labor costs by having a single foreign worker handle multiple positions. This report clarifies the regulations and practical situations concerning foreign workers working at multiple workplaces within Vietnam, and explains the key points that companies should be aware of to ensure compliance with regulations and to avoid labor risks.

1. Foreign workers working at multiple workplaces

Foreign workers working at multiple work locations within Vietnam are mainly classified into the following two cases.

The first case is where a foreign worker is employed by a single employer (company) but actually has multiple work locations, either in the same or different provinces or cities. This form is often seen in companies that have subordinate units such as resident offices, branches, or sales locations separate from the headquarters.

The second case involves foreign workers who work at multiple independent companies within Vietnam. In group companies that have multiple subsidiaries, it is sometimes seen that a foreign parent company assigns a single foreign worker as a manager or specialist to multiple subsidiaries within Vietnam. There are also cases where foreign workers work individually at several companies that do not belong to the same group.

2. Points to consider regarding foreign workers working at multiple workplaces

When foreign workers are employed at multiple work locations within Vietnam, whether within a single company or across multiple companies, there are more procedures and more complex issues compared to working at a single work location. Therefore, employers (companies) and workers need to pay close attention to the following points.

2.1. When employed by a single employer and working at multiple work locations

Regarding work permits:
In principle, foreign workers are only permitted to work according to the details specified on their work permit. Therefore, if they are to work at multiple work locations, companies must obtain work permits corresponding to each work location. If the work locations span multiple provinces or cities, the application for the work permit falls under the jurisdiction of the Ministry of the Interior. On the other hand, if there are multiple work locations within the same province or city, it falls under the jurisdiction of the local office of the Ministry of the Interior. However, in practice, the application procedures to the Ministry of Home Affairs remain complicated, and many companies take the approach of individually applying for work permits through the local home affairs bureaus for each work location.

Regarding the conclusion of employment contracts:
The obligation to conclude employment contracts for foreign workers who work at multiple locations within a single company is determined based on the “work form” specified on each work permit. Under labor law, if the work permit specifies “work style according to the labor contract,” the company must conclude a labor contract with the foreign worker based on that content. Therefore, companies need to verify the work style indicated on the work permit and properly carry out the necessary labor contract procedures.

Regarding the application for visa and residence card:
Even if a foreign worker works at multiple workplaces, only one visa application is needed, and after that, obtaining just one residence card is sufficient to be recognized as staying legally in Vietnam. It is not necessary to obtain separate residence cards for each workplace.

2.2. When employed by multiple employers and working at multiple workplaces

Regarding the work permit:
Companies employing foreign workers, whether subsidiaries within the same group or completely unrelated independent companies, are each considered separate legal entities under Vietnamese law. Therefore, each company must individually obtain work permits necessary for employment for each of their foreign workers. In other words, a work permit obtained for one company cannot be used for working at another company. However, if a foreign worker who has already obtained a valid work permit works for another company in the same occupation and position, there is a preferential measure that exempts the submission of a health certificate and a certificate of no criminal record for the second and subsequent work permit applications. By utilizing this system, companies can reduce the time and cost of procedures.

Regarding the conclusion of the labor contract:
As with working at a single company, all companies that have an employment relationship with foreign workers need to check the “work mode” stated on the work permit and determine whether it is necessary to conclude a labor contract.

Regarding the application for visas and residence cards:
Even if foreign workers work at multiple companies, it is sufficient for one company to handle the application for visas and residence cards. It is advisable that the parties involved discuss and agree in advance on which company will handle the visa and residence card application procedures.

3. Points to Note Regarding Social Insurance, Health Insurance, and Personal Income Tax

3.1 Obligation to Enroll in Social Insurance and Health Insurance

When foreign workers are employed at multiple work locations, each employer must pay attention to the following two points.

① Confirmation of whether foreign workers are required to enroll in social insurance and health insurance
Not all foreign workers are required to join social insurance and health insurance in Vietnam. Obligation to enroll arises only when all of the following conditions are met.
 ・The duration of the labor contract is 12 months or longer.
 ・The worker does not fall under any of the following categories.
  ○ Internal company transfer (employment type specified on the work permit qualifies as this).
  ○ The person has already reached the retirement age at the time of signing the labor contract.

② Confirmation of the payment destination for social insurance and health insurance.
If it is mandatory for foreign workers to enroll, the payment method varies depending on their work arrangement.
 ・In cases where there are multiple work locations within a single company: Both the company and the foreign worker can carry out the procedure at either the social insurance office located at the company’s head office or at the social insurance office in each branch (such as branches or representative offices).
 ・In cases where a person works for multiple companies (holding multiple employment contracts): If enrollment is mandatory at all companies, the process is handled according to the following principles.

Social Insurance Health Insurance Workers’ Accident ・Occupational Disease Insurance
Enrollment based on the initially concluded labor contract (*)  Enrollment based on the labor contract under which social insurance is enrolled (in principle, the first labor contract)  Enrollment based on all labor contracts

Moreover, if a foreign worker is employed at a company where they are excluded from insurance coverage, the company is obligated to pay an amount equivalent to the insurance premium (employer’s contribution) in addition to the salary.

3.2. Regarding Personal Income Tax

Foreign workers are obligated to file and pay personal income tax on all income earned from all workplaces within Vietnam, regardless of whether they work for one or multiple companies. However, there are differences in tax obligations depending on the distinction between residents and non-residents, as well as the number of workplaces.

Item   Vietnam Resident Vietnam Non-Resident
Multiple work locations within a single company Multiple companies employment Multiple work locations within a single company Multiple companies employment
Taxable Income Income from all work locations within Vietnam Income from all work locations within Vietnam All income generated within Vietnam is subject to taxation. All income generated within Vietnam is subject to taxation.
Tax Rate Progressive taxation (5% to 35%) Progressive taxation (5% to 35%) Flat 20% Flat 20%
Year-End Adjustment If salary income is from only one company and currently employed, delegation is possible Self-declaration required No year-end adjustment required No year-end adjustment required

In Conclusion

When employing foreign workers at multiple work locations, it is important for companies to first accurately grasp the actual labor conditions and consult government agencies as needed in order to smoothly apply the working arrangements in compliance with laws and regulations. Based on that, by properly handling various procedures such as obtaining work permits, visas, and residence cards, concluding labor contracts, and fulfilling obligations related to social insurance, health insurance, and personal income tax, companies can minimize legal risks.

References
– 2019 Labor Law
– Decree No. 152/2020/ND-CP (partially amended by Decree No. 70/2023/ND-CP)
– 2024 Social Insurance Law
– 2024 Amended Health Insurance Law
– Personal Income Tax Law and related decrees and circulars
– Decision No. 595/QD-BHXH (partially amended by Decision No. 888/QD-BHXH)
(*) There are no specific provisions at this time, but the principles of social insurance contributions for Vietnamese workers are applied mutatis mutandis based on Article 2, Clause 5, Point a of the 2024 Social Insurance Law

This article was translated by Yarakuzen.

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