Currently, in export activities involving goods and services, Vietnamese enterprises are required to use two types of invoices simultaneously:
- Electronic Value-added tax (VAT) Invoice – for tax declaration and reporting to Vietnamese tax authorities;
- Commercial invoice – for sending to foreign partners to serve international transactions.
Issuing both invoices for the same transaction leads to administrative burdens, increases the risk of data errors, consumes time, and raises operational costs. The new Decree 70/2025/ND-CP (Decree 70) was recently introduced on 20 March 20 2025, which provides a new approach to invoicing for export activities.
Decree 70: Allows commercial e-invoices to replace VAT invoices in export activities
According to Clause 2a, Article 8 of Decree 70/2025/ND-CP, effective from 1 June, 2025, exporters of goods or services are allowed to use commercial e-invoices in place of VAT e-invoices, provided they meet the following conditions:
- Transmit commercial invoice data electronically to the tax authority;
- The invoice must comply with content requirements in Article 10 and standard data format requirements in Article 12 of Decree 123/2020/ND-CP.
If the conditions are not met, businesses must continue using VAT e-invoices or sales e-invoices as before.
A more specific and clear definition of invoice issuance time
Under Article 9 of Decree 70, the time for issuing export invoices (including for export processing) is no longer limited to the term “customs clearance” as before, but is now defined more clearly: “The time of issue of an electronic commercial invoice, electronic VAT invoice or electronic sales invoice shall 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 custom”
This provides businesses with flexibility in determining the invoice issuance time while still ensuring compliance with tax obligations.
Implementation in practice: easier said than done?
Although the new regulation provides a positive direction by simplifying the invoicing process, actual application remains challenging:
- Foreign partners or intermediaries (e.g., parent companies, OEMs, international delivery providers) often require Vietnamese companies to use their custom invoice templates or to generate invoices directly on their systems.
- Partners may have different requirements regarding invoice content, while the invoice format supported by the Vietnamese tax system is limited and difficult to customize.
- As a result, even when companies meet the legal requirements to use electronic commercial invoices, many are still unable to apply them in practice.
Therefore, many businesses still have to issue both VAT and commercial invoices for the same export transaction.
What should businesses do?
To adapt to the new regulation, businesses may consider the following:
- If possible, negotiate with foreign partners to agree on using a single commercial e-invoice, based on the Vietnamese standard format that is compatible with the local tax system.
- If the partner’s invoice format cannot be changed, businesses should:
– Establish a cross-check process between the VAT and commercial invoices.
– Ensure consistency of information to avoid discrepancies that could lead to tax issues.
RBA WTS Vietnam stands ready to support you in navigating these changes, providing expert guidance and practical solutions tailored to your needs. For further clarification or personalized consultation, please contact us.
