In alignment with our commitment to keeping clients informed of regulatory developments impacting business operations in Vietnam, we would like to highlight the key updates under Decree No. 70/2025/ND-CP. This new Decree, effective from 1st June, 2025, amends and supplements certain provisions of Decree No. 123/2020/ND-CP on invoices and records. Notably, it introduces new requirements for foreign suppliers, revised invoicing timelines, and clarifications regarding e-invoice handling and corrections. Below, we summarize the critical changes to help your business adapt seamlessly.
| No | Items | Decree No.70/2025/ND-CP | Decree No.123/2020/ND-CP |
| 1 | Regulated entities | Foreign suppliers that do not establish permanent establishments in Vietnam, engage in e-commerce, digital platform-based business and provide other services, and voluntarily register for use of e-invoices in accordance with regulations herein: • Will submit applications for use of e-invoices via the General Department of Taxation’s web portal dedicated to foreign suppliers that do not establish permanent establishments in Vietnam. • Use electronic VAT invoices. | This subject is not regulated. |
| 2 | Invoicing time | For export of goods (including processing of goods for export), the time of issue of an electronic commercial invoice, electronic VAT invoice or electronic sales invoice will be determined by the seller provided that such an invoice must be issued no later than the working day following the day on which the goods are granted customs clearance in accordance with regulations of law on customs. | This subject is not regulated. |
| Time of issue of an invoice for provision of services is the time of completion of provision of services (including provision of services to foreign organizations or individuals), irrespective of whether the payment of the invoiced amount is made or not. | Invoices for provision of services shall be issued upon completion of the provision of services, whether the payment of the invoiced amount is made or not. | ||
| 3 | Invoices generated by POS cash registers and digitally connected to tax authorities | Subject to apply: • Any household business or individual business has annual revenue of at least VND 1 billion. • Enterprises selling goods and providing services, including sale of goods or provision of services directly to consumers (shopping malls; supermarkets; retailers (except automobiles, motorcycles, motorbikes and other motor vehicles); foods and drinks; restaurants; hotels; passenger transport services, road transport support services, arts, entertainment, cinema and other personal services as prescribed in Vietnam Standard Industrial Classification) | Not regulated subject to apply |
| 4 | Invoice types | Exporters (including processors of goods for export) can use invoice types when exporting goods or services as follows: • Electronic commercial invoices if an exporter meets conditions for transmitting data on electronic commercial invoices to tax authorities using electronic means. • Electronic VAT invoices or electronic sales invoices if an exporter fails to meet conditions for transmitting data on electronic commercial invoices to tax authorities using electronic means. | E-invoices used by exporters only include VAT invoices or electronic sales invoices. |
| Export processing enterprises that perform other business activities (in addition to export processing activities as prescribed by law on industrial parks and export-processing zones) and declare VAT using the direct method will use sales invoices. Export processing enterprises that declare VAT using the credit-invoice method will use VAT invoices. | This content is not regulated. | ||
| 5 | Name of goods/ services, unit, quantity, unit price | For sales promotion as prescribed by law on commerce, gifting or donation of goods/services in accordance with regulations of law, an invoice for total value of goods/services used for sales promotion, gifted or donated will be issued and accompanied with the list of goods/services used for sales promotion, gifted or donated. | This content is not regulated. |
| 6 | Replacement and correction of e-invoices | If information on the buyer, name of goods, unit price and/or tax rate on multiple invoices issued to the same buyer in a month is wrong, the seller is allowed to issue an invoice to correct or replace all of the erroneous ones issued in the month and accompany it with a list of erroneous e-invoices using Form No. 01/BK-DCTT in Appendix IA enclosed with Decree No.70/2025/NĐ-CP. Before correcting or replacing an erroneous invoice: • If the buyer is an enterprise, economic organization, other organization, household business or individual business, the seller and the buyer will have a written agreement showing the errors. • If the buyer is an individual, the seller will inform the erroneous invoice to the buyer or on the seller’s website (if any). | This content is not regulated. |
| 7 | The digital signature on an e-invoice is different from the issuance date | The date of the digital signature and the date on which the issued invoice is sent to the tax authority for grant of authentication code (for an authenticated invoice) or the date on which the e-invoice data is transferred to the tax authority (for an unauthenticated invoice) will not be later than the working date following the issuance date of the invoice | This content is not regulated. |
| For tax declaration: • The seller: The date of tax declaration will be the issuance date of the invoice • The buyer: The date of tax declaration will be the date of receipt of the invoice which is issued in the correct format and contains adequate information as regulated. | Not separated the date of tax declaration for seller and buyer, just mentioned the date of tax declaration is issuance date of the invoice. | ||
| 8 | Handling of e-invoices in case of return of goods or services | If the buyer returns all or part of the goods (including exchange of goods which results in a change in the value of the purchased goods): • Seller will issue a correction invoice; or • If agreed upon between the parties, the buyer can issue an e-invoice for the returned goods. | In this case, the seller issues a return invoice to adjust or replace the invoice already issued, and the seller and buyer have an agreement stating the return of goods. |
We encourage all businesses, especially those engaged in cross-border transactions and digital services, to review the revised regulations carefully and assess their invoicing practices accordingly. Our team at RBA WTS Vietnam stands ready to support you in interpreting and implementing these updates to ensure full compliance. For any specific questions or tailored advice, please do not hesitate to contact us.
Disclaimer: This summary is for informational purposes only and does not constitute legal advice. Consult a professional for specific recommendations.
