Dong Nai has taken back the site of a five-star hotel complex that never got built. Under Decision 3194/QD-UBND of 6 October 2026, the city government reclaimed 11,628.9 m² in Tran Bien ward, formerly Thong Nhat ward in Bien Hoa, from Berjaya–D2D Co., Ltd. The land was allocated in 2008 and 2009. Eighteen years on, the case is a clear signal to anyone sitting on a hotel land bank: under the 2024 Land Law, provinces can and do take back land, without compensation.

Key facts

  • Decision: 3194/QD-UBND, Dong Nai City People’s Committee, 6 October 2026. Effective 20 October 2026.
  • Land: 11,628.9 m², made up of Lot A (7,696.9 m²) and the five-star hotel area (3,932 m²).
  • Original allocation: Decisions of 29 August 2008 and 27 May 2009, for a “complex and five-star hotel” project.
  • Reason: The extended land-use deadline expired before construction was completed. Clause 8, Article 81 of the 2024 Land Law.
  • Final extension: Three months, granted by Decision 1454/QD-UBND on 14 April 2026, with a warning of reclamation without compensation.
  • Next steps: The company must hand over its land-use certificates and the land to the city’s Land Fund Development Centre. Tax authorities will check and collect any unpaid land charges. The Finance Department will deal with the investment procedures for the project.

What happened

Berjaya–D2D was set up in 2008 by Berjaya Leisure (Cayman), a subsidiary of Malaysia’s Berjaya group, and Industrial Urban Development JSC No. 2 (D2D, listed on HOSE), with charter capital of US$20 million. D2D contributed land worth US$5 million for 25%, and Berjaya held 75%.

CafeF reports that D2D announced in 2018 it had sold its whole stake for nearly VND116bn, citing losses. Yet the national business registry, updated in September 2025, still lists D2D with 25%, alongside Berjaya’s 75%, on charter capital of VND320bn. We could not resolve that conflict.

In April 2026 the old Dong Nai province gave the company three more months, on condition that it paid an extra charge equal to the land rent, completed its legal paperwork and sped up construction. The authorities found that the project was not completed.

Why it matters

Vietnam’s provinces have hundreds of hotel and mixed-use sites allocated in the 2000s and 2010s that are still vacant. Older rules let them sit through repeated extensions. The 2024 Land Law gives a fixed path: an extension, then reclamation with no compensation for land, assets or remaining investment costs.

For Bien Hoa, the decision also frees a central plot in an industrial city that will sit close to Long Thanh airport.

What it means for you

1. Owners with stalled sites should check their deadlines now

If your hotel land has passed its put-into-use deadline, or is on an extension, the clock is real. Build a schedule you can evidence, because “in progress” no longer protects a site.

2. Investors: reclaimed sites come back to market

Land reclaimed by the Land Fund Development Centre is usually re-allocated through auction or tender. Developers looking at Dong Nai near Long Thanh airport should watch for this plot.

3. JV partners: registry records matter

The conflicting reports on D2D’s stake show how stale registrations can leave partners exposed to a failed project. Check the national business registry, not just press releases, before you do a deal.

4. Lenders: discount land banks held on extensions

Collateral that can be reclaimed without compensation is worth much less than its book value. Underwrite on the build schedule.

FAQ

Who owned the Bien Hoa five-star hotel site?

Berjaya–D2D Co., Ltd, a joint venture of Berjaya Leisure (Cayman), part of Malaysia’s Berjaya group, and D2D.

Why was the land reclaimed?

The company’s extended deadline to put the land into use expired before it finished building the approved project. That falls under Clause 8, Article 81 of the 2024 Land Law.

Will the company be compensated?

The April 2026 extension decision said the land would be taken back without compensation for land, assets on it or remaining investment costs.

When does the decision take effect?

On 20 October 2026.