Regulatory updates - Vietnam

The new rules replace and consolidate the existing e-invoicing regime under Decree 123, provide implementation guidance for the Law on Tax Administration 2025, and introduce several operational changes affecting invoice issuance, reporting obligations, invoice content requirements, and tax administration processes. 

Key updates include, among others: 

1. Clarification of e-invoicing scope 

• A defined list of transactions is provided that are not subject to e-invoicing requirements, including internal transfers, financial and insurance transactions, asset transfers or capital contributions, and machinery or equipment lent without transfer of ownership. 

• Additional guidance is introduced for areas that were previously not specifically addressed, including digital cross-border services, certain financial transactions, and activities carried out by household and individual businesses. 

2. E-invoice and e-document issuance rules 

• Deposits paid solely to secure the performance of a service contract do not trigger an invoice issuance obligation. 

• Suppliers that do not use automated e-invoicing software and conduct sales during night working hours can issue invoices on the next working day. 

• Additional mandatory invoice fields are introduced, impacting e.g. household and individual businesses, as well as selected B2C transactions and sales of vehicles and transportation services.

3. Conversion of e-invoices into paper format 

• E-invoices may only be converted into paper format for audit, inspection or accounting record purposes. 

• Converted invoices cannot be used for commercial transactions or payment purposes, except e.g. invoices generated by point of sale (POS) systems. 

• Paper receipts may continue to be used until December 31, 2026, while from 1 January 2027, electronic receipts will become mandatory. 

Decree 254 and Circular 91 entered into force on July 1, 2026. The new rules introduce a more comprehensive regime for the management of e-invoices and e-documents, while bringing additional compliance and administrative obligations for taxpayers.

On June 17, 2025, Resolution No. 204/2025/QH15, which reduces the Value Added Tax (VAT) rate from 10% to 8% until December 31, 2026, was approved. The aim is to continue boosting production and promoting business activities in the country. 

The 2% VAT reduction, from 10% to 8%, applies to the goods and services specified in Article 9, Clause 3 of the Law on Value Added Tax No. 48/2024/QH15, except for certain groups of goods and services, such as telecommunications, financial activities, banking, securities, insurance, real estate business, metal products, mining products (except coal), and goods and services subject to special consumption tax (except gasoline). 

This Resolution expands the range of entities eligible for the tax reduction compared to previous National Assembly Resolutions and extends the tax reduction period from July 1, 2025, to December 31, 2026. 

Consequently, transportation, logistics, goods, and information technology services are eligible for tax reduction. Further details are expected to be provided by the Government.

On May 31, 2025, the Ministry of Finance published Circular No. 32/2025/TT-BTC, which offers additional guidance on invoices and related documents under the Law on Tax Administration 2019 and Decree No. 123/2020/ND-CP, amended and supplemented by Decree No. 70/2025/ND-CP.

The key aspects include:

• Authorization of a third party for e-invoice issuance: Details the requirements for the content of the contractual agreements, notifications to the tax authority, and additional details that should be shown on invoices issued by a third party.
• Invoice numbering format: Outlines the form number and reference code for different types of e-invoices and pre-printed invoices, including VAT and sales invoices, as well as new invoice types such as e-commerce invoices and combined VAT- and sales-invoices with tax, fee, and charge receipts. Additional details include the structure of invoice codes, which reflect tax authority codes, the year of creation, and invoice type.
• Guidance for specific invoice scenarios: Clarifies invoicing for regular, large-scale transactions and financial leasing, detailing compliance requirements. Specifies the content required for VAT invoices that also serve as tax refund declarations.
• Requirements when switching to e-invoice regime: Describes the procedures for taxpayers transitioning to electronic invoices with tax authority codes.
• Identification of high-risk taxpayers: Outlines the criteria for identifying taxpayers with high tax risks, such as past violations and unclear operations, when registering for electronic invoicing.
• Criteria for e-invoice service providers: Defines the standards that service providers must meet.
• Personal income tax certificates: Organizations that deduct personal income tax are required to discontinue the use of electronic personal income tax deduction certificates based on previous regulations and should transition to using electronic certificates in compliance with Decree No. 70/2025/ND-CP.
• Lucky invoice program: Encourages end consumers to request an invoice through a ‘lucky invoice’ award program administered by the Tax Department.

Circular No. 32/2025/TT-BTC replaces Circular No. 78/2021/TT-BTC dated September 17, 2021, and is effective from June 1, 2025.