Form 5472 for Vietnam Residents with a US LLC
No US-Vietnam tax treaty is in force, and Vietnamese tax codes became personal ID numbers in 2025. What Vietnam-based LLC owners file on Form 5472.
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Last updated September 18, 2026
A Vietnam-resident owner of a US single-member LLC must file Form 5472 with a pro forma Form 1120 for each year the LLC had a reportable transaction with them. No US-Vietnam tax treaty is in force (the 2015 treaty never took effect), and since 1 July 2025 a Vietnamese individual's tax code is their personal identification number.
Developers in Hanoi, agency owners in Da Nang, ecommerce operators in Ho Chi Minh City and long-staying remote workers form Wyoming, Delaware and Florida LLCs mainly for US payment processors and US business banking. Stripe, PayPal and a Mercury or Relay account are far easier to obtain behind a US entity.
Two features of the Vietnam position change the mechanics of the filing compared with a UK or Indian owner: there is no treaty in force to reach for, and the number Vietnam issues individual taxpayers changed form in 2025. Neither removes the obligation.
If you would rather have the filing done than explained, we prepare and fax the complete package from $149.
Do Vietnam residents have to file Form 5472?
Yes, on the same terms as any other non-US owner. Three conditions:
- The LLC is a US disregarded entity - a single-member LLC that has not elected corporate treatment.
- Its sole member is a non-US person: not a US citizen, green card holder or US tax resident.
- There was at least one reportable transaction during the tax year between the LLC and its owner or another foreign related party.
Under Treasury Regulation section 1.6038A-1, for tax years beginning on or after 1 January 2017 and ending on or after 13 December 2017, a foreign-owned US disregarded entity is treated as a corporation separate from its owner solely for the section 6038A reporting rules. That treatment exists only to make the information return possible; it does not turn the LLC into a taxpaying corporation, and it applies whether you have lived in Vietnam for ten years or arrived last month.
The filing is year by year. A year in which nothing moved between you and the LLC may need no Form 5472, but the year you formed the LLC almost always does, because putting money into a new account to open it is itself a contribution.
Reportable transactions are money, property or services moving between you and your own LLC. Customer revenue is not reportable. A Stripe payout from a customer never goes on the form; a transfer from that balance to your personal Vietcombank or Techcombank account does.
| Movement during the year | Reportable on Form 5472? |
|---|---|
| Client pays the LLC's Stripe or Wise account | No - customer revenue |
| You convert VND and wire capital in to open the LLC's US account | Yes - contribution |
| You move USD from the LLC to your personal Vietnamese account | Yes - distribution |
| You lend the LLC money to pay a supplier | Yes - loan |
| The LLC pays a Vietnamese company you also own | Yes - and that company is a second related party |
The IRS instructions state that a $25,000 penalty may apply for failure to file when due and in the prescribed manner, a substantially incomplete Form 5472, or failure to maintain required records, and that filing a substantially incomplete form constitutes a failure to file. It is not automatic for every mistake.
Does the US-Vietnam tax treaty change anything?
No, because there is no US-Vietnam income tax treaty in force. Vietnam does not appear on the IRS's United States income tax treaties A to Z list. Under the letter V, the page lists Venezuela and nothing else.
This is where most content for Vietnam-based founders goes wrong. An agreement does exist on paper: the US Treasury publishes the signed Agreement between the U.S. and Vietnam for the Avoidance of Double Taxation, dated 7 July 2015. It reads like any treaty in force. It is not one. A signed treaty that has not entered into force gives a taxpayer nothing: no article to invoke, no reduced rate, no competent authority to approach. We take no position on why it never took effect, because we cannot source that.
The consequences split cleanly into two columns:
| Item | Unchanged by the absence of a treaty | Removed by the absence of a treaty |
|---|---|---|
| The Form 5472 obligation | Unchanged - section 6038A is domestic US law | - |
| The pro forma Form 1120 route | Unchanged | - |
| No e-filing; fax or mail to Ogden | Unchanged | - |
| The $25,000 penalty exposure | Unchanged | - |
| FTIN and reference ID mechanics in Part II | Unchanged | - |
| Reduced withholding on US-source passive income | - | Removed - no treaty rate to substitute |
| Permanent establishment protection | - | Removed - US business income is decided under US domestic law alone |
| Any treaty-based return position or treaty claim | - | Removed - there is no article to claim |
| Mutual agreement relief from double taxation | - | Removed - no competent authority procedure |
Everything that makes up the Form 5472 filing sits in the left column. The right column matters to owners with US-source passive income or US-based operations, who should take professional advice on US taxability. If you have been told a Vietnam treaty lowers your US withholding or protects your US profits, ask the person telling you to show you Vietnam on the IRS list; it is not there.
What goes in the FTIN box for a Vietnam-resident owner?
Enter your Vietnamese tax code. Since 1 July 2025, a Vietnamese citizen's tax code is their 12-digit personal identification number; a foreign national keeps the 10-digit tax code the tax authority issued them.
The change came from Circular 86/2024/TT-BTC, issued by Vietnam's Ministry of Finance on 23 December 2024. The Government of Vietnam's news service reported that personal identification numbers replace tax codes for households, business households, individuals and dependents from 1 July 2025, using the 12-digit number issued by the Ministry of Public Security.
| Part II line | Vietnam-resident individual owner | Notes |
|---|---|---|
| Line 4b(1), US identifying number | Only if you already hold an SSN, ITIN or EIN | Most owners leave this blank |
| Line 4b(2), reference ID number | A self-assigned alphanumeric ID | Required when 4b(1) is blank; identical every year |
| Line 4b(3), FTIN | Your Vietnamese tax code (a citizen's 12-digit personal ID number, or a foreign national's issued 10-digit tax code) | Enter "None" only if you hold no foreign tax number |
A foreign national resident in Vietnam should use whichever Vietnamese tax number is currently valid for them and keep it consistent. A company's tax code is not your personal FTIN. Do not apply for a US ITIN merely to fill the box; the reference ID exists for owners without a US number. Our FTIN and reference ID guide covers the edge cases.
Use your actual Vietnamese address in Part II, not the LLC's US registered agent address.
Does Vietnamese personal tax affect the US filing?
No. Vietnamese personal income tax and the US Form 5472 obligation run on separate tracks.
In outline, the Law on Personal Income Tax, Law No. 109/2025/QH15, passed on 10 December 2025 and effective from 1 July 2026, defines a resident in Article 2 as a person present in Vietnam for 183 days or more in a calendar year or in 12 consecutive months from first arrival, or having a place of habitual residence there - a registered permanent residence or a house rented under a fixed-term contract. Residents are taxable on income arising inside and outside Vietnam; non-residents on income arising inside Vietnam. One timing detail matters if you are resident: although the law as a whole takes effect on 1 July 2026, Article 29(2) applies its rules on a resident individual's business income and salary income from the 2026 tax period — the whole of 2026, not just the second half.
How Vietnam treats your US LLC's profits is a question of Vietnamese law. Ask a Vietnamese tax adviser or the tax authorities; we do not advise on Vietnamese tax.
On visas: we could not confirm from any Vietnamese government source that Vietnam offers a dedicated digital-nomad or remote-worker visa. The Vietnam Immigration Department's portal at immigration.gov.vn lists e-visas, visas through overseas missions and checkpoints, temporary residence declaration, ABTC cards and passports, with no such category shown. That absence is not a formal statement, so treat the question as unverified and ask the Immigration Department. Your visa status does not affect Form 5472.
How does a Vietnam-based owner actually file?
You cannot e-file. The package goes to the IRS by fax or mail.
- Prepare the pro forma Form 1120 with "Foreign-owned U.S. DE" across the top of page 1. Only the name and address and items B and E are required.
- Prepare Form 5472 - Part I for the LLC, Part II for you with your Vietnamese address, tax code and reference ID, Part III for the related party, Part IV for monetary transactions, and a Part V statement itemising contributions and distributions.
- Convert VND to US dollars at a reasonable rate for each transaction date, applied consistently, and state the basis in the Part V statement.
- Sign the pro forma 1120.
- Fax to 855-887-7737, or mail to Internal Revenue Service, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201.
- Keep the fax receipt. It is transmission evidence, not IRS acceptance of the return.
The due date for a calendar-year entity is generally 15 April; Form 7004 extends it. See our deadline guide.
Getting it filed from Vietnam
No treaty to invoke, an FTIN that changed form in 2025, VND conversion with a stated basis and a possible second related party are routine once handled before - and exactly the details that make a do-it-yourself form substantially incomplete.
Form5472 Prep prepares Form 5472, the pro forma Form 1120 and the Part V statement, has a qualified tax accountant review the package, faxes it to the IRS Ogden PIN Unit and returns the timestamped receipt.
$149 standard, ready in 5-7 business days. $199 express, within 3 business days. +$99 per additional past tax year. IRS fax delivery included.
We are not a CPA firm and do not give tax advice, in the US or in Vietnam. We prepare and submit the US information return.
Start your filing - about 15 minutes.
Frequently asked questions
Is there a US-Vietnam tax treaty I can rely on?
No. The IRS treaty A-to-Z list does not include Vietnam. An agreement was signed on 7 July 2015 and the US Treasury publishes its text, but it has not entered into force, so it gives you no article to claim.
Does the absence of a treaty mean I skip Form 5472?
No. Form 5472 is required by US domestic law under section 6038A. Treaties allocate taxing rights over income; none exempts anyone from this information return.
What FTIN do I enter as a Vietnamese resident?
Your Vietnamese tax code: a citizen's 12-digit personal ID number since 1 July 2025, or a foreign national's issued 10-digit tax code. Add a self-assigned reference ID number and keep it identical every year.
I already pay Vietnamese personal income tax. Does that cover this?
No. The Vietnamese return is a tax return filed in Vietnam. Form 5472 is a US information return about transactions between you and your LLC. Filing one does not satisfy the other.
Does Vietnam have a digital nomad visa?
We could not confirm one from a Vietnamese government source, so treat it as unverified and ask the Vietnam Immigration Department. Either way, your visa changes nothing about Form 5472.
My LLC received $80,000 from clients and I sent myself $60,000. What is reportable?
The $60,000 you sent yourself is a reportable distribution. The $80,000 of customer revenue is not a related-party transaction and does not go on the form.
I have never filed and my LLC is two years old. What now?
File every outstanding year promptly with a reasonable cause statement, before the IRS writes to you. Each year carries its own exposure. See our late filing guide.
The missing treaty removes options you might have hoped for and removes nothing from the filing. If money moved between you and your US LLC this year, Form 5472 is due.
File from Vietnam in about 15 minutes, or compare another no-treaty jurisdiction in our UAE and Dubai guide.
Splitting the year across several countries? The Form 5472 guide for digital nomads covers filing when you have no single tax residence.
Educational content only; not tax or legal advice.