Regulatory updates - Vietnam

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.

On March 20, 2025, the Vietnamese Government published Decree No. 70/2 025/ND-CP, which includes essential regulatory updates for electronic invoicing and supporting documents, set to take effect as of June 1, 2025.

This decree amends and supplements a range of articles in Decree No. 123/2020/ND-CP, “The government regulating invoices and documents” from 2020, and aims to enhance compliance, simplify e-invoice issuance, and improve integration with the tax authority’s systems by clarifying taxpayers, intermediaries, and software providers' responsibilities.

Some of the main changes include the following.

• Extended scope: Compliance requirements for foreign suppliers without a permanent establishment in the country, including digital platform-based businesses and companies engaged in e-commerce activities. These requirements involve implementing specific timelines for issuing invoices across different transactions. This group of companies may voluntarily register to issue electronic VAT invoices.
• Invoice issuance and timings:
  
  • Sellers, including individual businesses, are allowed to appoint a third party for invoice issuance following a written agreement;
  • Clarifications on invoice types are provided for 'export processing enterprises' involved in additional business activities beyond export and processing. These clarifications outline whether electronic sales invoices or electronic VAT invoices should be used based on these companies’ tax declaration method;
  • Businesses are allowed to issue e-commerce invoices when exporting goods or services, provided they meet the content, format, and transmission requirements;
  • For exported goods, sellers may decide when to issue the invoice, but it must be no later than the workday following the customs clearance of the goods;
  • Additional amendments concerning the issuance timing for specific scenarios, such as the sale of national reserve goods and sectors, e.g., credit institutions, insurance businesses, passenger transport, and retail trading.
• Invoice content: 
  
  • Invoices must include additional information such as budget-related unit code or the personal identification number of end consumers, as provided by the buyer;
  • If the digital signature time differs from the e-invoice issuance time, the invoice must be submitted to the tax authority no later than the next working day after the e-invoice was issued.
• Rectification process: 
  
  • The invoice cancellation process is replaced by either adjustment or replacement processes, depending on the specific scenario;
  • Before adjusting or replacing an e-invoice, the buyer and seller must have a written agreement specifying any incorrect content for B2B invoices. For B2C transactions, the seller must either notify the buyer or announce it on their website;
  • It is allowed to issue one invoice to replace or adjust multiple incorrect invoices issued in the same month to the same buyer;
  • Additional clarification for invoice scenarios when goods are returned.

• Extended scope for cash register e-invoices: 
  
  • Business households, individual businesses with annual revenue of 1 billion VND (approximately 34,000 EUR) or more, and companies with B2C transactions, such as shopping centers, supermarkets, restaurants, and passenger transportation services, are required to use e-invoices generated by cash registers connected to tax authorities for data transmission.

Decree 70 also introduces numerous amendments and additions to certain forms and report templates. Additionally, the list of prohibited actions includes failing to transmit electronic data to tax authorities and forging invoices and documents.

Businesses operating in Vietnam and their tax advisors are recommended to review and analyze this decree’s impact on their business models and compliance requirements.

On November 26, 2024, Vietnam’s National Assembly passed a new Value Added Tax (VAT) Law, Law 48/2024/QH15, which will come into effect on July 1, 2025. The new VAT Law will replace the existing VAT Law No. 13/2008/QH12 and its amendments.

The new VAT Law introduces significant changes and simplifies the regulatory framework by consolidating the provisions from previous decrees and amendments.

What are the main changes?

• Widened taxpayer definition:The new VAT law includes obligations for foreign suppliers without a permanent establishment in Vietnam, e.g., foreign suppliers engaging in e-commerce with both organizations and individuals, and foreign organizations operating on digital platforms.
• Time of Determining VAT Liability: The timing of VAT liability is now explicitly regulated in the law. VAT obligations are triggered:
  • for goods at the time of the transfer of the ownership or the right to use the goods;
  • for services, when the provision of services is completed; or
  • at the time when an invoice is issued, regardless of whether payment has been received (applicable to both goods and services).
• Increased VAT exemption threshold: The VAT exemption threshold for businesses, households, and individuals will be increased from lower than 100 million (ca. 3.820 EUR) VND to lower than 200 million VND (ca. 7.640 EUR).

Reclassified VAT Rates

Some items have been reclassified, for example:

• 0% rate - The rate will apply to the export of goods and services provided for consumption outside of Vietnam, goods and services provided directly to organizations within tax-free zones including an additional requirement of directly serving export production activities.
• 5% rate - This rate will apply to specialized machinery and equipment used for agricultural production, animal feed, and fertilizers; offshore fishing vessels are reclassified and will be subject to the 5% VAT (previously exempt from VAT).
• 10% rate - Services supplied through e-commerce or digital platforms by foreign suppliers without a permanent establishment in Vietnam, such as film production, import, and distribution (previously subject to the 5% rate).

Furthermore, it should be noted that more detailed and specific not-subject-to-VAT rules will apply to some goods and services, such as plant and forest products, plant breeding materials, life insurance, health insurance, agricultural insurance services, insurance of ships and boats, insurance of oil and gas works, and equipment.

Finally, it’s worth highlighting that to continue boosting consumption and support production, Resolution No. 174/2024/QH15 extends the reduced VAT rate from 10% to 8% for certain goods and services, specified in Resolution No. 43/2022/QH15, until the end of June 2025.