Decree 181/2025/NĐ-CP (effective from 1 July 2025) provides detailed guidance on multiple key provisions of VAT Law No. 48/2024/QH15, including conditions for input VAT credit on purchased goods and services, as well as on exported goods and services.
This article summarises the essential requirements for VAT credit, special cases, and regulations on cashless payment vouchers.
1. General Conditions for Input VAT Credit
To be eligible for input VAT credit, enterprises must simultaneously meet the following requirements:
1.1. Possession of Valid Invoices
According to Article 25 of Decree 181/2025, valid documents include:
- VAT invoices for purchased goods and services; or
- Import VAT payment documents; or
- VAT payment documents on behalf of foreign contractors (calculated as a percentage of revenue).
1.2. Cashless Payment Vouchers (for invoices of VND 5 million or more)
According to Article 26:
- Applicable to purchase invoices with a total payment value of VND 5 million or more;
- Payment vouchers must comply with the regulations in Decree 52/2024/NĐ-CP on cashless payments.
Cash deposits made by buyers into sellers’ bank accounts are not accepted.
2. Special Cases Relating to Cashless Payment Vouchers
Decree 181/2025 lists numerous special circumstances, with several key groups that enterprises should note:
2.1. Offset Payments
Including offsets through:
- Barter transactions;
- Offsetting mutual receivables/payables between two parties;
- Offsetting through a third party.
Requirement:
A reconciliation record or tripartite offset agreement is required.
2.2. Borrowing/Lending Transactions or Loan Offsets
Enterprises must have:
- A pre-existing loan/borrowing agreement; and
- Bank transfer documents.
2.3. Payments through Third Parties
Includes authorised payments or payments made under sellers’ instructions.
Condition: Must be clearly stated in the contract, and the third party must be legitimate.
2.4. Payments in Shares or Bonds
- A written sale/purchase agreement executed beforehand is required.
2.5. Installment or Deferred Payments
Input VAT credit is allowed before the due date; however:
- If no cashless payment voucher is available by the due date → the credited VAT must be adjusted and reduced.
2.6. Purchases Under VND 5 Million per Transaction
- Cashless payment vouchers are not required.
- However, multiple purchases made on the same day with a total of VND 5 million or more → cashless payment vouchers are required.
3. Conditions for Input VAT Credit on Exported Goods and Services
According to Article 27, to claim input VAT related to exported goods and services, enterprises must prepare a complete set of documents.
3.1. Export Documentation Package
Including:
- Export contract or entrusted export contract;
- Sales invoice / VAT invoice;
- Completed customs declaration;
- Cashless payment vouchers from overseas;
- Packing list, bill of lading, insurance documents (if applicable).
3.2. Special Cases Related to Payment Documentation
The Decree specifies more than 20 detailed scenarios. Some notable cases include:
- Offsetting payments against foreign loans;
- Using export proceeds as capital contribution for overseas investment;
- Payments made by overseas parties via third parties;
- Payments from non-resident bank accounts in Vietnam;
- Foreign private enterprises paying through personal accounts;
- Cases where overseas buyers become insolvent;
- Exported goods damaged and destroyed, or suffering losses verified by competent authorities;
- Goods rejected by overseas buyers and resold to another customer in the same country.
All such cases require written explanations with supporting alternative documents.
4. Conditions for VAT Credit on Goods Exported via Foreign Ecommerce Platforms
According to Article 28, enterprises exporting goods via foreign e-commerce platforms must have:
- A contract with the e-commerce platform operator;
- Sales invoice;
- Completed customs declaration;
- Cashless payment vouchers (may be through an intermediary collecting entity);
- Documents proving delivery to overseas buyers.
Decree 181/2025/NĐ-CP introduces extensive practical scenarios to:
- Reduce tax risks for enterprises;
- Standardise payment documentation;
- Clarify mechanisms for offsets, authorised payments, and third-party payments;
- Provide greater transparency on export documentation.
Enterprises should carefully review payment vouchers, contracts, and export documentation to ensure eligibility for VAT credit and avoid disallowed deductions during tax audit or inspection.
