Official Letter No. 2193/CT-CS dated April 8, 2026, issued by the Tax Department on VAT and invoice policies:
by KMC Consulting Company Limited
The Tax Department provides responses to issues regarding value-added tax (VAT) and invoice policies raised by the Tax Department of Can Tho City.
On November 13, 2025, the Tax Department received Official Letter No. 203/CTH-QLDN4 dated July 14, 2025, from the Tax Department of Can Tho City concerning VAT and invoice policies. Regarding this matter, the Tax Department provides the following opinions:
(1) Regarding e-invoices generated from cash registers
- Pursuant to Clause 2, Article 91 of the Law on Tax Administration No. 38/2019/QH14 regarding the application of e-invoices for the sale of goods and provision of services;
- Pursuant to Clause 8, Article 1 of Decree No. 70/2025/NĐ-CP dated March 20, 2025, amending the title of Article 11 and supplementing Article 11 of Decree No. 123/2020/NĐ-CP dated October 19, 2020 on e-invoices generated from cash registers;
- Pursuant to Clause 5, Article 12 of Circular No. 32/2025/TT-BTC dated May 31, 2025 of the Ministry of Finance guiding implementation provisions.
The Tax Department of Can Tho City is requested to rely on the above regulations and, based on the actual application of invoices by enterprises, ensure that such invoices constitute electronic data in accordance with Clause 5, Article 12 of Circular No. 32/2025/TT-BTC for proper handling in compliance with regulations.
(2) Regarding invoicing for collection activities on behalf of competent state authorities
- Pursuant to Point a, Clause 7, Article 1 of Decree No. 70/2025/NĐ-CP dated March 20, 2025, amending and supplementing Clause 5, Article 10 of Decree No. 123/2020/NĐ-CP on invoice contents.
Accordingly:
- Where the buyer does not have a tax identification number (TIN), such TIN is not required to be shown on the invoice.
- For certain specific cases of sale of goods or provision of services to individual consumers as prescribed in Clause 14, Article 10 of Decree No. 123/2020/NĐ-CP, the buyer’s name and address are not required to be shown on the invoice.
- Where the buyer provides a TIN or personal identification number, such information must be stated on the invoice.
(3) Regarding VAT policy for sales discounts and returned goods
- Pursuant to Article 47 of the Law on Tax Administration No. 38/2019/QH14 regarding supplementary tax declarations;
- Pursuant to Clause 6, Article 6 of Law No. 56/2024/QH15 dated November 29, 2024 amending and supplementing Article 47 of the Law on Tax Administration;
- Pursuant to Article 7 of Decree No. 126/2020/NĐ-CP dated October 19, 2020 on tax declaration dossiers;
- Pursuant to Clause 6, Article 23 of Decree No. 181/2025/NĐ-CP dated July 1, 2025 on VAT crediting;
- Pursuant to Clause 3, Article 40 of Circular No. 80/2021/TT-BTC dated September 29, 2021 on recovery of tax refunds.
Accordingly:
Where a taxpayer has been granted a VAT refund for exported goods but such goods are returned, the taxpayer must submit a supplementary tax declaration in accordance with Article 47 of the Law on Tax Administration and Article 7 of Decree No. 126/2020/NĐ-CP. At the same time, the taxpayer must repay the refunded amount corresponding to the returned exported goods and pay late payment interest in accordance with Article 59 of the Law on Tax Administration and Article 21 of Circular No. 80/2021/TT-BTC to the state budget, calculated from the date the State Treasury disbursed the refund or offset the refund against state budget revenues.
(4) Regarding declaration of omitted input invoices
- Pursuant to Point d, Clause 1, Article 14 of the Law on VAT No. 48/2024/QH15 dated November 26, 2024 on input VAT credit;
- Pursuant to Clause 6, Article 23 of Decree No. 181/2025/NĐ-CP dated July 1, 2025 on VAT crediting.
Accordingly:
Where a business establishment detects errors or omissions in declared input VAT, it may make a supplementary declaration before the tax authority or competent authority announces a tax inspection or audit decision. The taxpayer shall declare as follows:
- Make a supplementary declaration in the tax period in which the input VAT error or omission occurred if such declaration increases the payable tax amount or reduces the refundable tax amount of that period;
- Declare in the period in which the error or omission is detected if declaring in the original period would reduce the payable tax amount or only increase/decrease the input VAT carried forward to subsequent periods.
(5) Regarding VAT declaration and refund for investment projects
- Pursuant to Point a, Clause 2, Article 15 of the Law on VAT No. 48/2024/QH15 dated November 26, 2024 on VAT refunds;
- Pursuant to Clause 1, Article 30 and Clause 1, Article 39 of Decree No. 181/2025/NĐ-CP dated July 1, 2025 on VAT refunds for investment projects and transitional provisions;
- Pursuant to Point d, Clause 2, Article 7 of Decree No. 126/2020/NĐ-CP dated October 19, 2020 on tax declaration dossiers.
Accordingly:
Where an investment project, as reported by the Tax Department of Can Tho City, does not fall under the transitional provisions specified in Clause 1, Article 39 of Decree No. 181/2025/NĐ-CP, the Tax Department of Can Tho City is requested to review taxpayers eligible to file Form No. 02/GTGT – VAT Declaration (applicable to taxpayers applying the credit method with investment projects eligible for VAT refund) issued together with Circular No. 80/2021/TT-BTC dated September 29, 2021 of the Ministry of Finance.