Recently, the Khanh Hoa Provincial Inspectorate has released the conclusions of a specialized inspection of projects facing difficulties, obstacles, delays, and low efficiency in the province.
Based on the list of 15 projects issued under Decision No. 65/QĐ-TTT dated July 28, 2025, by the Chief Inspector of Khanh Hoa Province regarding the specialized inspection of investment projects with difficulties, obstacles, delays, and low efficiency in Khanh Hoa Province (Inspection Team No. 2), the inspection agency has suspended the inspection of 6 projects: Bao Dai Luxury Resort Project; Bach Viet Hotel (Bavico) Project; The Horizon Nha Trang Hotel Project; Sweet Homes Plaza Hotel and Residence (Ocean Gate Hotel & Residence) Project; Green World Nha Trang 2 Hotel Project; and Khatoco Commercial and Hotel Complex Project.
Thus, the inspection team only conducted inspections on 9 projects, including: Nha Trang Vocational College Project, Ho Tien Sports and Tourism Service Area; Lotte Nha Trang Comprehensive Trade Center Project; Prime Resorts and Hotels Eco-Tourism Project;…
Notably, among these 9 projects, the inspection results of the International Marina Park Project have several noteworthy points.
Image: Tecco Group
The International Marina Park Project (Bac Nha Trang Ward, Khanh Hoa); The initial investor was Trong Diem Co., Ltd. After approximately 3 years of implementation, Trong Diem Co., Ltd. transferred the investment of the project to its subsidiary, Ana Marina Nha Trang Co., Ltd.
On October 12, 2017, the Provincial People’s Committee issued Decision No. 3023/QĐ-UBND approving the investment policy for Ana Marina Nha Trang Co., Ltd.
The project covers an area of approximately 89.3 hectares (including land, rocky areas, and water surface); after adjustments, it is 390,299 m². The investment capital is 388 billion VND, with a self-funded capital ratio of 40% and a loan ratio of 60% (according to the latest adjustment).
Project Transfer Not in Compliance with Regulations
According to the conclusions of the Khanh Hoa Provincial Inspectorate, the change of legal entity implementing the project from Trong Diem Co., Ltd. to Ana Marina Nha Trang Co., Ltd. constitutes a project transfer.
The transfer of the real estate project did not meet the requirements for transfer documents (including: project transfer registration document; project transfer contract; document on the legal status of the transferee; report on the project implementation status).
The inspection agency holds the Provincial People’s Committee, the Department of Planning and Investment of Khanh Hoa Province in 2014, and related individuals responsible.
Regarding the separation of Ana Marina Park Co., Ltd. from Ana Marina Nha Trang Co., Ltd. and the separation of the project, Ana Marina Nha Trang Co., Ltd. has requested adjustments to the project’s location, scale, and initial total investment.
According to the inspection conclusions, the enterprise separation is basically in line with investment laws. However, upon inspection from the date of the first Investment Registration Certificate 3302785616 until now, Ana Marina Park Co., Ltd. has not implemented the project in Zone III, covering nearly 53.6 hectares.
Through discussions, the company stated that the investor has constructed some infrastructure, technical facilities, and park landscapes on an area of 5,419.8 m² (Zone IIIA-2); Zone III-C2 (boat mooring area) with an area of 530,556.8 m² has not been implemented due to obstacles related to land allocation, lease regulations, and adjustments to the general and detailed planning (1/2000 scale).
Therefore, the investor lacks the legal basis to implement the project, leading to delays as per the Investment Certificate. Currently, the project is not operational, and there have been no transfers or leases.
Trong Diem Co., Ltd. Leased Land Without Auction
The inspection conclusions state that on November 1, 2013, the Khanh Hoa Provincial People’s Committee issued Decision No. 2764/QĐ-UBND leasing land to Trong Diem Co., Ltd. for project implementation (covering 879,679.1 m² of coastal water surface) without an auction of land use rights, violating Article 58 of the 2003 Land Law.
The separation of part of the project from Ana Marina Nha Trang Co., Ltd. to Ana Marina Park Co., Ltd., which has not implemented the project for 9 consecutive years (from 2016 to 2025), falls under the category requiring revocation of the Investment Certificate according to Article 48 of the Investment Law No. 61/2020/QH14 dated June 17, 2020.
Additionally, the legal investment documents have been transferred to Ana Marina Nha Trang Co., Ltd., and Ana Marina Park Co., Ltd. is implementing them, but the legal land documents (Decision No. 2764/QĐ-UBND dated November 1, 2013) have not been adjusted in a timely manner; synchronized with the land user according to the project’s legal investment documents, thus lacking the legal basis to determine and fulfill land-related financial obligations for the project.
The inspection agency holds the Provincial People’s Committee, the Department of Natural Resources and Environment of Khanh Hoa Province in 2013, and related individuals responsible for these violations.
Furthermore, on June 26, 2017, the Khanh Hoa Department of Construction issued a construction permit for Zone II (rocky area, beach reclamation of nearly 20.6 hectares) to Ana Marina Nha Trang Co., Ltd., while Trong Diem Co., Ltd. was the land leaseholder, which does not comply with regulations.
Regarding land price determination and fulfillment of land-related obligations, according to Official Letter No. 1811/STC dated May 9, 2016, from the Khanh Hoa Department of Finance on the land rental price for the International Marina Park Project, the land rental price for areas in Zone II, Zone IIIA, and IIIB is 1,110,113 VND/m². According to the inspection agency, this land price does not consider land improvement factors, as the investor provided project estimate documents and land improvement costs that are not appropriate.
Based on these conclusions, the Khanh Hoa Provincial Inspectorate proposes that the Provincial People’s Committee recommend to the Steering Committee 751 and the Prime Minister to report to competent authorities for approval to apply special mechanisms similar to those in Resolution No. 170/2024/QH15 to address land use continuation, land price determination, and full payment of project obligations into the state budget, ensuring no loss of state budget funds.
Regarding Ana Marina Nha Trang Co., Ltd., the company was established in 2014 with a charter capital of 116.4 billion VND; the capital contributors include Trong Diem Trading and Tourism Co., Ltd. with 51%, Mr. Nguyen Duc Chi with 30%, Mr. Dang Bao Hieu with 7.6%, Mr. Dang Bao Loc with 5.7%, and Mr. Nguyen Duc Tan with 5.7%.
In September 2018, before converting to a joint-stock company, Ana Marina Nha Trang had a charter capital of 520 billion VND. The shareholders included 2 organizations and 1 individual, with Focus Vietnam Holdings JSC holding 65%, Tecco Group JSC holding 30%, and Mr. Cao Huu Nhanh holding 5%.
In January 2019, the company transitioned to a joint-stock company, with Mr. Dang Bao Hieu as the General Director and legal representative. As of the latest update in March 2025, Ana Marina Nha Trang increased its charter capital from 940 billion VND to 980 billion VND. The Chairman of the Board is Mr. Dang Bao Hieu, and the General Director is Mr. Dao Truong Tuan.
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