Pursuant to the “Prohibited Market Access List” (Appendix I-A) of Decree 31/2021/ND-CP (“Decree 31”) supporting the implementation of the new Law on Investment (LOI 2020), majority foreign investment in goods transshipment business is prohibited.
"Article 3. Definitions
For the purposes of this Law, the terms below are construed as follows: 
1. Investment policy approval means the competent/authorized State agency approves the objectives, location, scale, schedule and duration/term of project implementation; and the investor or form of investor selection and special mechanisms or policies (if any) in order to implement the investment project […]
10. “market access conditions applied to foreign investors” mean those which must be satisfied by foreign investors to make investment in the List of business lines with prohibited and restricted market access (hereinafter referred to as “the Negative List for Market Access”) specified in Clause 2 Article 9 of this Law. 
11. Investment registration certificate ["IRC"] means a written or electronic document recording information registered by an investor about an investment project. [...]
19. “foreign investor” means an individual holding a foreign nationality or an organization established under foreign laws and carrying our business investment activities in Vietnam.
20. “domestic investor” means an individual holding Vietnamese nationality or a business organization whose members or shareholders are not foreign investors. 
[...]
Article 4. Application of the Law on Investment and relevant laws
1. Business investment activities in the territory of Vietnam [must] comply with the Law on investment [this Law] and other relevant laws.
2. If there is any discrepancy between the provisions of this Law and those of another law issued before the effective date of this Law in relation to the industries and trades in which business investment is prohibited, or industries and trades in which business investment is conditional, then the provisions of the Law on investment [this Law] shall prevail. [...]
3. If there is any discrepancy between the provisions of this Law and those of another law issued before the effective date of this Law in relation to the sequence and procedures for business investment and investment security [guarantee], then implementation shall accord with this Law except for the following cases: [...]
(d) Implementation of investment projects for construction, for residential housing and for urban zones are implemented in accordance with the provisions of the Law on Construction, the Law on Residential Housing and the Law on Real Estate Business after the competent agency has approved the investment policy or the amended investment policy in accordance with the provisions of this Law;
(dd) Authority, sequence, procedures and conditions for business investment implemented in accordance with the Law on Credit Institutions, the Law on Insurance Business, and the Law on Petroleum;
(e) Authority, sequence, procedures and conditions for business investment and activities on the securities market implemented in accordance with the Law on Securities.
[...]
Article 9. Business lines with prohibited and restricted market access and market access conditions applied to foreign investors
1. Market access conditions applied to foreign investors are the same as those applied to domestic investors, except for the case specified in Clause 2 of this Article.
2. Pursuant to Laws and Resolutions of the National Assembly, Ordinances and Resolutions of the Standing Committee of the National Assembly, Decrees of the Government and international treaties to which the Socialist Republic of Vietnam is a signatory, the Government shall promulgate a Negative List for Market Access, including:
a/ Prohibited business lines;
b/ Restricted business lines.
3. Market access conditions applied to foreign investors specified in the Negative List for Market Access include:
a/ Holding of charter capital by the foreign investor in a business organization;
b/ Investment method;
c/ Scope of investment;
d/ Capacity of the investor; partners participating in the investment activities;
dd) Other conditions specified in the Laws and Resolutions of the National Assembly, Ordinances and Resolutions of the Standing Committee of the National Assembly, Decrees of the Government and international treaties to which the Socialist Republic of Vietnam is a signatory. [...]" (Law on Investment No. 61/2020/QH14 of 17 June 2020 [google translation])
------------------------------------
"Section 2. SECTORS, LINES AND MARKET ACCESS CONDITIONS FOR FOREIGN INVESTORS
Article 15. Sectors and trades restricted from market access for foreign investors
1. Sectors and trades with restrictions on market access for foreign investors and restrictions on market access for such industries and trades are prescribed in laws and resolutions of the National Assembly, ordinances and resolutions. of the National Assembly Standing Committee, Government decrees and international treaties on investment. The list of industries and trades with restrictions on market access for foreign investors is published in Appendix I of this Decree.
2. Market access conditions for foreign investors shall be applied in the forms specified in Clause 3, Article 9 of the Law on Investment and posted and updated according to the provisions of Article 18 of this Decree.
3. In addition to the market access conditions for the industries and trades specified in Clauses 1 and 2 of this Article, foreign investors and foreign-invested economic organizations when conducting business investment activities Businesses in Vietnam must satisfy the following conditions (if any):
a) Use of land and labor; natural resources, minerals;
b) Producing and supplying public goods and services or goods and services that are monopolistic in the state;
c) Owning and trading in houses and real estate;
d) Applying forms of support and subsidies of the State to a number of branches and fields or developing regions or territories;
dd) Participating in the program and plan for the equitization of state-owned enterprises;
e) Other conditions as prescribed in laws and resolutions of the National Assembly, ordinances and resolutions of the National Assembly Standing Committee, decrees of the Government and international treaties on investment that do not allow allow or restrict market access for foreign-invested economic organizations.
Article 16. Subjects of application of the List of industries and trades restricted from market access
1. The list of industries and trades with restricted market access applies to:
a) Foreign investors as prescribed in Clause 19, Article 3 of the Law on Investment ;
b) The economic organization specified at Points a, b and c, Clause 1, Article 23 of the Law on Investment when investing in the establishment of other economic organizations; make capital contribution, purchase shares, purchase capital contribution portion of other economic organizations; investment in the form of BCC contract.
(In this Section, the subjects specified at Points a and b of this Clause, hereinafter collectively referred to as foreign investors, unless otherwise provided for by this Decree).
2. For business investment activities carried out in Vietnam, investors who are Vietnamese citizens and hold foreign citizenship are entitled to choose to apply market access conditions and investment procedures as follows: regulations applicable to domestic or foreign investors. In the case of choosing to apply market access conditions and investment procedures as prescribed for domestic investors, investors who are Vietnamese citizens and have foreign nationality are not entitled to exercise their rights. and regulatory obligations for foreign investors.
Article 17. Principles of applying restrictions on market access for foreign investors
1. Except for the industries and trades on the List of industries and trades with restricted market access for foreign investors specified in Appendix I of this Decree, foreign investors are entitled to market access as prescribed. for domestic investors.
2. Foreign investors are not allowed to invest in industries and trades that have not yet been able to access the market as prescribed in Section A, Appendix I of this Decree.
3. For industries and trades with conditional market access for foreign investors as prescribed in Section B, Appendix I of this Decree, foreign investors must satisfy the conditions for market access. Schools are posted according to the provisions of Article 18 of this Decree.
4. Market access conditions for industries and trades that Vietnam has not yet committed to market access to for foreign investors are applied as follows:
a) Where laws and resolutions of the National Assembly, ordinances and resolutions of the National Assembly Standing Committee, decrees of the Government (hereinafter referred to as Vietnamese law) do not contain provisions restricting access to the market for that industry or trade, foreign investors may access the market as prescribed for domestic investors;
b) Where Vietnamese law already contains provisions on restricting foreign investors' market access for such industries or trades, the provisions of Vietnamese law shall apply. [...]
7. Foreign investors belonging to countries or territories that are not members of the WTO and conducting investment activities in Vietnam are entitled to the same market access conditions as those applicable to national investors. a territory that is a member of the WTO, unless otherwise provided for by Vietnamese law or an international treaty between Vietnam and that country or territory.
[...]
APPENDIX I - LIST OF INDUSTRY AND LINES LIMITED MARKET ACCESS FOR FOREIGN INVESTORS 
A. INDUSTRY AND LINES THAT HAVE NOT BEEN ACCESSED TO THE MARKET FOR FOREIGN INVESTORS
1. Trading in goods and services on the list of goods and services subject to state monopoly in the field of commerce.
2. Press activities and news gathering activities in all forms.
3. Catching or harvesting marine life.
4. Investigation and security services.
5. Judicial administrative services, including judicial expertise services, bailiff services, property auction services, notary services, and services of asset administrators.
6. Service of sending workers to work abroad under contract.
7. Invest in building infrastructure for cemeteries and graveyards to transfer land use rights associated with infrastructure .
8. Garbage collection service directly from households.
9. Public opinion polling service (opinion poll).
10. Blasting service.
11. Producing and trading in weapons, explosives and supporting tools.
12. Import and dismantle used ships.
13. Public postal service.
14. Goods transshipment business.
15. Trading in temporary import for re-export.
16. Export, import, and distribute goods featuring on the list of goods that foreign investors and foreign-invested economic organizations are not allowed to export, right import and distribution rights.
17. Collection, purchase and disposal of public property at units of the armed forces.
18. Manufacture of military materials or equipment; trading in military equipment, military equipment for the armed forces, military weapons, equipment, techniques, weapons, specialized military and police vehicles, components, parts, spare parts, supplies and special equipment, specialized technology to manufacture them;
19. Industrial property representation service business and intellectual property assessment service.
20. Services of setting up, operating, maintaining and maintaining navigational signals, water zones, waters, public navigational channels and navigational routes; survey services of water areas, water areas, public navigational channels and navigational routes serving the publication of maritime notices; survey services, building and publishing charts of water areas, seaports, navigational channels and routes; develop and publish maritime safety documents and publications.
21. Regulatory services to ensure maritime safety in water zones, waters and public navigational channels; maritime electronic information services.
22. Inspection services (inspection and testing) and issuance of certificates for means of transport (including systems, components, equipment and components of vehicles) ; services of inspection and issuance of certificates of technical safety and environmental protection for specialized vehicles, equipment, containers, and equipment for packing dangerous goods used in transportation; inspection services and grant of certificates of technical safety and environmental protection for means and equipment for oil and gas exploration, exploitation and transportation at sea; dTechnical inspection service for occupational safety for machines and equipment with strict requirements on occupational safety installed on means of transport and vehicles, exploration and mining equipment and transporting oil and gas at sea; fishing vessel registration service.
23. Services of investigation, assessment and exploitation of natural forests (including logging and hunting, trapping of rare and precious wild animals, management of genetic funds of plants, animals and microorganisms used in agriculture).
24. Research or use genetic resources of new livestock breeds before being appraised and evaluated by the Ministry of Agriculture and Rural Development.
25. Travel services, except international travel services for inbound tourists.[...]"(Government Decree on the Elaboration of Some Articles of the Law on Investment No. 31/2021/ND-CP of 26 March 2021 [google translation] (Decree 31), which provides guidance on the implementation of the new Law on Investment [google translation])
Law on Investment No. 61/2020/QH14 of 17 June 2020 [google translation]
Government Decree on the Elaboration of Some Articles of the Law on Investment No. 31/2021/ND-CP of 26 March 2021 [google translation]
[<a href="https://vbpl.vn/bokehoachvadautu/Pages/vbpqen-toanvan.aspx?dvid=312&ItemID=11133">Law</a>],[<a href="https://vbpl.vn/bokehoachvadautu/Pages/vbpq-toanvan.aspx?ItemID=147720&Keyword=31/2021/ND-CP">Decree</a>],[<a href="https://static1.squarespace.com/static/50c0b136e4b01ad287768e06/t/6246f475c7499050ffab3d02/1648817271960/2022+3+30+Decree+31.2021+implementing+Investment+Law+2020+1.2.pdf">Other</a>],[<a href="https://www.allenandgledhill.com/vn/perspectives/articles/18840/vnkh-issues-new-guidance-on-foreign-investment">Other</a>]