VIFC vs DIFC, AIFC, and GIFT City: How Vietnam's Financial Centre Compares

Why these three comparators#

There are dozens of international financial centres worldwide. The VIFC's natural comparison set is not London, New York, or Singapore — centres with decades of institutional depth and global capital markets infrastructure that Vietnam is not attempting to replicate overnight.

The relevant peer group is the cohort of purpose-built, emerging-market IFCs that share a similar strategic logic: carve out a special legal and regulatory zone within a developing economy, offer preferential terms to attract international financial institutions, and use the IFC as a lever for broader economic modernisation.

Three centres fit that description most closely:

DIFC (Dubai) — the most mature of the group, now in its third decade, and the benchmark against which newer IFCs are inevitably measured. Established in 2004, it is the largest regulated financial ecosystem in the Middle East, Africa, and South Asia.

AIFC (Astana) — launched in 2018 and modelled partly on the DIFC. The AIFC has moved aggressively into digital assets and capital markets, positioning Kazakhstan as a financial gateway between China, Central Asia, and Europe. A Vietnamese delegation led by the Deputy Prime Minister visited the AIFC in February 2026.

GIFT City (Gujarat, India) — India's sole international financial services centre, operational since 2015 with a unified regulator (IFSCA) since 2020. It serves primarily as an offshore-onshore bridge for Indian capital flows, with growing ambitions in fund management, aircraft leasing, and insurance.

Each offers lessons — and cautionary tales — for the VIFC.

The snapshot comparison#

Before the detail, here is the headline picture. All figures are as of late 2025 or early 2026 unless noted.

The numbers tell one story. The architecture tells another. Below is where the differences actually matter.

Legal systems: the fundamental design choice#

The single most consequential architectural decision an IFC makes is which legal system governs transactions within its boundaries.

DIFC and AIFC both adopted common law systems, deliberately importing English-law principles, English-language legislation, and judges from common law jurisdictions. The rationale is straightforward: international financial contracts — derivatives, structured finance, fund documentation, M&A — overwhelmingly use English-law or New York-law governing clauses. A common law IFC reduces the friction of transplanting those contracts into a new jurisdiction.

The DIFC has operated its independent common law courts since 2006, with judges drawn from England, Singapore, Hong Kong, and other common law jurisdictions. Its legal database comprises dozens of bespoke DIFC laws covering companies, employment, insolvency, foundations, trusts, and more. The AIFC followed a similar path, with its Court and International Arbitration Centre hearing cases under common law rules and offering hearing rooms in eight countries across Eurasia.

GIFT City takes a different approach. It operates under Indian statute law, with IFSCA regulations layered on top. There is no separate court system — disputes are resolved through Indian courts, with IFSCA providing the regulatory layer. This means GIFT City's legal certainty is anchored in India's existing judicial infrastructure, which is deep but not always fast.

The VIFC has made a hybrid choice. The centre operates within Vietnam's civil law tradition, but Resolution 222 and the eight implementing decrees create a specialised legal space with distinctive features: a dedicated Specialised Court (established by a separate National Assembly law in December 2025), an International Arbitration Centre that can apply foreign governing law in defined circumstances, and English as a permitted operating language alongside Vietnamese.

This is not common law. But it is not standard Vietnamese civil law either. The VIFC's legal architecture attempts to provide the predictability that international financial participants need without fully transplanting a foreign legal system — a compromise that reflects both political constraints and a pragmatic assessment of what Vietnam's institutions can sustain.

"The VIFC's legal architecture is a bet that you can deliver enough predictability for cross-border finance without importing English common law wholesale. Whether that bet works depends on how the Specialised Court actually operates — its judges, its procedures, its willingness to enforce international arbitral awards."

The practical question for firms: If your standard documentation assumes common law concepts — trust structures, equitable remedies, implied terms — the DIFC and AIFC offer the most familiar legal terrain. If you operate primarily in Asian civil law jurisdictions and are comfortable with Vietnamese legal concepts supplemented by international arbitration, the VIFC's hybrid model may be sufficient. GIFT City works best for firms already embedded in the Indian legal ecosystem.

Regulation: unified, independent, or layered?#

How regulation is structured within an IFC determines how quickly licences are issued, how consistently rules are applied, and how much bureaucratic friction firms encounter.

DIFC has the most established model: the Dubai Financial Services Authority (DFSA) is a fully independent regulator with its own rulebooks, supervisory staff, and enforcement powers. It operates separately from the UAE's federal Capital Market Authority. As of end 2025, the DFSA regulated 1,052 entities. The DFSA's track record — two decades of licensing decisions, enforcement actions, and rule-making — gives it a level of institutional credibility that newer regulators cannot yet match.

AIFC followed a similar design with the Astana Financial Services Authority (AFSA), an independent regulator with jurisdiction over all financial activities within the AIFC. AFSA has been notably progressive on digital assets, licensing 19 digital asset service providers and issuing the first fiat-backed stablecoin licence in 2025. Its FinTech Lab regulatory sandbox has graduated seven participants to full regulatory status.

GIFT City created the International Financial Services Centres Authority (IFSCA) in 2020 as a unified regulator — replacing the separate jurisdiction of four Indian domestic regulators (RBI, SEBI, IRDAI, PFRDA) within the IFSC. This was a significant simplification. Rather than navigating four different regulators for banking, securities, insurance, and pensions, GIFT City firms deal with one authority. The IFSCA has issued comprehensive regulations covering fund management, capital markets, insurance, and banking.

The VIFC has adopted a layered model. The IFC Supervision Authority handles inspection, examination, and enforcement. But the IFC Executive Authorities in HCMC and Da Nang issue licences, including sandbox licences. The State Bank of Vietnam retains authority over banking supervision, monetary policy, and the foreign exchange framework. The Ministry of Finance is the standing agency of the Steering Committee and the licensing authority for the national crypto pilot.

This means VIFC firms may interact with multiple bodies — the relevant Executive Authority for their IFC licence, the SBV for banking and FX matters, the MOF for certain financial services, and the Supervision Authority for ongoing compliance. The layered model preserves the role of existing national regulators while creating dedicated IFC bodies. It is more complex than the DIFC or AIFC's single-regulator design, and the quality of inter-agency coordination will be a key variable in how smoothly the system operates in practice.

Tax: the headline and the detail#

Tax incentives are the most visible tool IFCs use to attract firms. The headline rates are easy to compare. The detail is harder.

DIFC: 0% corporate income tax for 50 years, guaranteed by Dubai law. No restrictions on foreign exchange or capital and profit repatriation. The simplicity is the selling point — there are no tiers, no sector conditions, no sunset clauses within the 50-year window.

AIFC: 0% CIT until January 1, 2066 for financial services, ancillary services, and dividends and capital gains on participants' shares. This is the most generous headline timeline in the comparison set. Like the DIFC, the exemption is broad rather than sector-specific.

GIFT City: A 10-year tax holiday on business income for IFSC units, with additional exemptions for non-residents on capital gains. The Finance Act 2025 extended pass-through status and exemptions. Compared to the DIFC and AIFC, the duration is shorter and the structure more complex, but the incentive is meaningful for firms operating within Indian tax parameters.

VIFC: A tiered system tied to the priority sector list in Decree 323. Projects in priority sectors — which include digital assets, DeFi, tokenisation, fintech, green finance, aviation finance, and maritime finance — receive a 10% CIT rate for 30 years. Projects in other IFC sectors receive 15% CIT for 15 years. Personal income tax exemptions on earned income for highly qualified personnel apply until 2030.

The VIFC's rate is not zero, which makes the headline comparison unfavourable against the DIFC and AIFC. But the 30-year duration for priority sectors is longer than GIFT City's holiday, and the 10% rate on profits is low enough to be competitive for most business models, particularly when combined with the sandbox mechanism's liability shields and the FX liberalisation under Circular 72.

The important detail is the priority sector mechanism. Vietnam has used the tax structure to steer activity toward specific sectors rather than offering a blanket exemption. This means the tax incentive is a policy tool, not just a competitive lever. Firms whose activities fall squarely within the priority list — digital assets, green finance, aviation finance, supply chain finance — get the best terms. Firms in adjacent sectors receive a still-attractive but less generous package.

Digital assets: from afterthought to founding pillar#

The four centres occupy very different positions on the digital asset spectrum.

DIFC arrived at digital assets gradually. The DFSA introduced its Investment Token regime in 2021 and has since built out a comprehensive framework covering crypto tokens, recognised tokens, and prohibited tokens. The DIFC now hosts 1,677 AI, fintech, and innovation-focused entities. But digital assets were not part of the centre's founding architecture — they were layered on two decades after establishment, as market demand evolved.

AIFC has been more proactive. AFSA licenses digital asset service providers under a dedicated framework, and in 2025 the ecosystem recorded $6.8 billion in digital asset transaction volume across 192,400 clients during the first three quarters. AFSA issued its first fiat-backed stablecoin licence and launched a pilot allowing regulatory fees to be paid in stablecoins. The AIFC's digital asset credentials are now substantial — but, like the DIFC, they were built through subsidiary regulations rather than embedded in the founding instruments.

GIFT City is the most cautious. IFSCA has been consulting on digital asset regulatory frameworks, but no comprehensive licensing regime is yet in place. India's broader policy stance on crypto — which has included a punitive 30% tax on gains and a 1% TDS on transactions — creates a more complex environment for digital asset businesses, even within the IFSC's ring-fenced structure.

The VIFC has taken the most aggressive founding position. As detailed in our analysis of Decree 323's priority sectors, the founding decree names DeFi, tokenisation, stablecoins, Web3, NFTs, and regtech as priority activities — entitled to 10% CIT for 30 years, sandbox access with liability shields, and streamlined licensing. Decree 330 permits NFTs structured as cultural and artistic products to be traded on commodity exchanges. Da Nang has already approved its first fintech sandbox trial — Basal Pay, a digital asset conversion project — and Binance signed an MOU with HCMC's Department of Finance in November 2025.

No other IFC in this comparison set has embedded digital assets this deeply into its founding legal architecture. Whether the VIFC can match this ambition with operational infrastructure — exchanges, custodians, clearing systems, surveillance — is the critical execution question.

Physical scale and city context#

IFCs do not exist in a vacuum. They operate within cities, and the city's own infrastructure, talent pool, liveability, and connectivity shape the IFC's attractiveness.

DIFC occupies 110 hectares in the heart of Dubai, beside Sheikh Zayed Road. A $27 billion expansion — the DIFC Za'abeel District — will roughly double the centre's footprint to over 150 hectares, with capacity for 42,000 companies and 125,000 professionals. Dubai itself is a global transit hub with extensive air links, zero personal income tax, and a well-established expat infrastructure.

AIFC is built on the former EXPO-2017 site in Astana. The city is Central Asia's largest and has invested heavily in modern infrastructure, but it lacks the air connectivity, climate, and lifestyle appeal of Dubai or Ho Chi Minh City. Kazakhstan's geographic position between China and Europe is strategically valuable for firms focused on Belt and Road or Central Asian markets.

GIFT City is located in Gandhinagar, Gujarat — India's administrative capital of Gujarat but not a major commercial or lifestyle centre. Access to Mumbai's financial ecosystem requires a short domestic flight. The infrastructure is purpose-built and modern, but the city does not yet offer the urban amenities or international schools that attract expatriate professionals and their families.

The VIFC has the largest physical footprint at 1,200 hectares across two cities. Ho Chi Minh City (898 hectares) is Vietnam's commercial capital — a metropolis of over 10 million people with growing air connectivity, a large expatriate community, international schools, and a cost of living significantly below Dubai or Singapore. Da Nang (300 hectares) is a mid-sized coastal city with strong IT infrastructure, 30+ universities, and a quality of life that consistently ranks among the best in Vietnam.

The dual-city model is unusual. Most IFCs concentrate in a single location to build density and network effects. Vietnam's approach distributes functions — Ho Chi Minh City as the comprehensive financial hub, Da Nang as the innovation and sandbox testing ground — which creates complementarity but also coordination challenges. The key infrastructure project to watch is the 55-storey Saigon Marina skyscraper in Thu Thiem, which will serve as the VIFC-HCMC headquarters.

Maturity and track record#

This is where the comparison is most stark — and most important to be honest about.

DIFC has been operating for over two decades. It has processed thousands of licences, resolved billions of dollars in court claims (over $4.7 billion in case values in 2025 alone), weathered the 2008 financial crisis, navigated the 2020 pandemic, and grown revenue to $580 million per year. Its institutional credibility is the product of time, not design.

AIFC has seven years of operations. It has built a functioning exchange (AIX, with $2 billion in trading turnover in 2025), attracted $20 billion in cumulative investment, and established a court that has handled 4,600+ cases. The trajectory is positive, but the track record is still developing.

GIFT City has been operational since 2015 with IFSCA since 2020. Its banking units have disbursed over $100 billion in dollar loans, and the fund management ecosystem has seen commitments surge to $26.3 billion. Its GFCI ranking at 46th globally reflects growing international recognition, but it remains a work in progress in many asset classes.

The VIFC launched in December 2025 and held its first formal member ceremony in February 2026. It has no track record. Its institutions exist in law but are still being stood up operationally. Its founding and strategic members are predominantly domestic Vietnamese institutions. No major international financial institution has publicly committed to establishing operations within the VIFC.

This is not a criticism — it is a statement of where the centre is in its lifecycle. Every IFC in this comparison started at zero. The DIFC's first years were spent attracting anchor tenants and proving that its legal system worked. The AIFC spent its early period building exchange infrastructure and licensing frameworks. The VIFC is at the same stage, with the same challenges.

The relevant question is not whether the VIFC currently matches the DIFC. It is whether the legal architecture, governance design, and policy commitments are credible enough to attract the first cohort of serious international participants — who will, in turn, attract the second.

What the VIFC does differently#

Rather than trying to replicate any single IFC model, the VIFC has made several distinctive architectural choices:

Dual-city structure. No other IFC in this comparison operates across two cities with separate Executive Authorities. This creates the possibility of regulatory competition and specialisation — Da Nang can experiment while HCMC scales — but also requires coordination mechanisms that other IFCs do not need.

Digital assets in the founding architecture. As discussed above, no peer IFC has named specific digital asset categories in its establishment instruments. This is Vietnam's clearest differentiation — an explicit, legally binding commitment to digital finance as a pillar of the centre from day one.

Ex post supervision model. The shift from ex ante licensing to ex post supervision for IFC members, implemented through Circular 72, is more aggressive than the DIFC or AIFC's approach, where licensing remains the primary gatekeeping mechanism. This places greater responsibility on firms and greater pressure on the Supervision Authority.

Civil law foundation with common law features. Rather than transplanting common law wholesale, the VIFC has created a hybrid — a specialised court within the civil law system, international arbitration with foreign governing law, English-language documentation. This is an experiment with no direct precedent among peer IFCs.

National-level political sponsorship. The VIFC's Steering Committee is chaired by the Prime Minister, with both city Party Secretaries as deputy heads. This level of political commitment is comparable to the DIFC's backing by the Ruler of Dubai, and arguably stronger than what the AIFC or GIFT City received at their founding stages.

The honest assessment#

The VIFC has an ambitious legal framework, strong political backing, and a clear willingness to compete on digital assets and regulatory innovation. Its cost structure — both the tax regime and the underlying cost of living in Ho Chi Minh City and Da Nang — is competitive. Its physical footprint is the largest in the comparison set.

What it lacks is everything that only time can provide: a track record of licensing decisions, a body of court judgments, a critical mass of regulated entities, a functioning exchange, and the institutional reputation that comes from years of consistent, predictable operation.

The DIFC took a decade to reach the scale and credibility it now enjoys. The AIFC is still building. GIFT City is still proving its model. The VIFC is at the very start of that journey.

For firms evaluating the VIFC, the comparison with peer IFCs is useful — but it should not be the deciding factor. The more relevant questions are practical: Does the VIFC's legal and regulatory framework accommodate your specific business model? Can you navigate the layered regulatory structure? Is the talent available? Can you operate in a civil law environment with the dispute resolution mechanisms provided?

Those questions can only be answered by engaging with the specifics — which is what the rest of VIFC Insight is designed to help with.

Quick-reference comparison table#

This guide will be updated as the VIFC's operational ecosystem develops and as comparator IFCs publish new data. Last verified: February 15, 2026.