The timing of issuing an invoice, is a critical compliance requirement for businesses operating in Vietnam. The regulations, primarily governed by Decree No. 123/2020/ND-CP (and subsequent amendments like Decree No. 70/2025/ND-CP), establish clear rules that determine when a Value Added Tax (VAT) or sales invoice must be issued, regardless of when payment is received.
General Rules for Invoice Issuance
1. For the Sale of Goods
The invoice must be issued at the moment the ownership or the right to use the goods is transferred to the buyer.
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This rule applies even if the seller has not yet collected payment from the buyer.
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For goods delivered multiple times, an invoice must be issued for the volume and value of goods corresponding to each individual delivery.
2. For the Provision of Services
The invoice must be issued at the time of completion of the service provision, regardless of whether the service fee has been collected or not.
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If the service is completed in stages or involves the handover of specific work items, an invoice must be issued for each completed stage or item.
Key Exceptions and Specific Cases
The general rules have important exceptions, especially concerning pre-payments and specific industry sectors:
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Pre-payments: If a service provider collects money before or during the provision of the service, the invoice must be issued on the date the payment is collected.
(excluding cases of collecting deposits or advances to ensure the performance of contracts for providing services: Accounting, auditing, financial and tax consulting; valuation; survey, technical design; supervision consulting; construction investment project preparation).
Note: In case of multiple deliveries or handover of each service item or stage, each delivery or handover must include an invoice for the volume and value of the goods and services delivered.
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Construction and Installation: The invoice must be issued at the time of acceptance and handover of the project, work item, or completed volume.
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Exported Goods: For goods subject to export, the seller has some flexibility but must issue the e-invoice no later than the working day following the date the goods are customs cleared.
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Oil and Gas/Electricity: For the sale of electricity or natural gas through transmission lines, the invoice is issued when the volume of gas or power is determined, with the deadline being no later than the last day of the tax declaration period.
Businesses must ensure their internal accounting and billing systems are aligned with these legal timelines. Failure to issue an invoice at the correct time is an administrative violation that can result in significant fines.