Official Letter No. 32591/CTBDU-TTHT regarding invoicing for machinery lending

In cases where a company engages in machinery lending activities, the company is required to issue an invoice. Upon the return of the machinery, the company must issue a return invoice following Clause 1, Article 4 of Decree No. 123/2020/ND-CP. The content of the invoice must comply with the provisions of Article 10 of the same decree. Additionally, suppose the depreciation expense of fixed assets during the lending period is not used for production or business activities. In that case, it cannot be included as a deductible expense when determining taxable corporate income, as stipulated in Article 4 of Circular No. 96/2015/TT-BTC.

The issuance of return invoices, as regulated under Clause 1, Article 4 of Decree No. 123/2020/ND-CP, is specified as follows:
Sellers of goods or providers of services must issue and deliver invoices to buyers in all cases, including:

• Goods and services used for promotion, advertising, or as samples.
• Goods and services are provided as gifts, exchanges, salary substitutes, or internal consumption (excluding internally circulated goods used for production).
• Goods are issued in the form of loans, leases, or returns.

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