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UPDATE ON ELECTRONIC INVOICE ISSUANCE – DECREE 70/2025/ND-CP AMENDING DECREE 123/2020/ND-CP

On March 20, 2025, the government issued Decree No. 70/2025/ND-CP to amend and supplement certain important provisions of Decree 123/2020/ND-CP concerning invoices and documents. This decree takes effect on June 1, 2025.

I/ EXTENDING THE SCOPE OF ELECTRONIC INVOICE USE

Foreign suppliers without a permanent establishment in Vietnam who engage in e-commerce, digital platform-based business, and other services may voluntarily register to use electronic invoices in accordance with this decree.

Organizations, enterprises, and individuals (exporters) who engage in the export of goods and services overseas, provided that the exporters meet the conditions for transmitting commercial invoice data electronically to the tax authorities. The electronic commercial invoices must comply with the content requirements outlined in Article 10 of this Decree and the data format standards of the tax authorities as specified in Article 12 of this decree.

II/ INVOICE ISSUANCE TIMING (Article 9) GENERAL PROVISIONSPDATE ON ELECTRONIC INVOICE ISSUANCE – DECREE 70/2025/ND-CP AMENDING DECREE 123/2020/ND-CP

III/ TYPES OF ELECTRONIC INVOICES

The decree adds provisions for certain types of electronic invoices:

  • Export processing enterprises engaged in other business activities (besides export processing as regulated by law on industrial zones and export processing zones) that declare VAT using the direct method must use sales invoices. Export processing enterprises declaring VAT using the credit method must use VAT invoices.
  • Electronic commercial invoices apply to organizations, enterprises, and individuals (exporters) involved in the export of goods and services, provided that the exporters meet the conditions for transmitting electronic commercial invoice data to the tax authorities. 
  • Electronic invoices with codes generated by cash registers: Decree 123 outlines general principles, while the amendment to Decree 123 further clarifies applicable cases, specific requirements, and introduces QR code provisions to allow buyers to look up invoices.

IV/ Invoice Content

Supplementary regulations related to the content of invoices in cases of promotional goods and services. Specifically

  • In cases of promotional goods and services in accordance with commercial law or goods and services given, donated, or gifted in compliance with legal regulations, an invoice shall be issued reflecting the total value of the promotional, donated, or gifted items, accompanied by a detailed list of such items.
  • Organizations must retain related documentation regarding promotional, donation, or gifting programs and provide it to competent authorities upon request. They are responsible for the accuracy of transaction information and must supply a detailed summary of goods and services upon request from the authorities.
  • In cases where customers request invoices for individual transactions, the seller must issue an invoice to the customer.
  • The invoice must clearly state “accompanied by Detailed List No. …, dated … day … month … year.” Detailed List must include the seller’s name, tax identification number, and address; the names of goods or services; quantities, unit prices, total values of goods and services sold; the issuance date; and the name and signature of the person preparing the statement.
  • If the seller pays value-added tax (VAT) using the deduction method, the Detailed List must include fields for “VAT rate” and “VAT amount.” The total payment amount must match the amount specified on the VAT invoice. Goods and services sold must be listed in the Detailed List statement in the order of sales during the day. The statement must specify “accompanied by Invoice No. …, dated … day … month … year.”
  • Specifically, the digital signature timestamp must not exceed one business day from the invoice issuance date.
  • In cases where the digital signature timestamp on an issued electronic invoice differs from the invoice issuance date, the digital signature timestamp and the time of submission to the tax authority for code issuance (for invoices with tax authority codes) or the time of data transfer to the tax authority (for electronic invoices without tax authority codes) must be no later than the next working day following the invoice issuance date, except for cases where data is submitted according to the summary report stipulated in point a.1, clause 3, Article 22 of this Decree

Tax declaration timeline:

  • Seller: At the time of invoice issuance.
  • Buyer: At the time of receiving the invoice, ensuring its accuracy and completeness in terms of format and content as stipulated in Article 10 of this Decree.

V/ REPLACEMENT AND ADJUSTMENT OF ELECTRONIC INVOICES