Exchange Rates for Export Transactions from 1 July 2026: Two Parallel Exchange Rates under Decree No. 252/2026/ND-CP
1. Exchange rate for accounting purposes
Under the guidance for Account 413 – Foreign Exchange Differences in Appendix II to Circular No. 99/2025/TT-BTC, when recognising export revenue, an enterprise must apply the actual transaction exchange rate at the recognition date. This is the average of the telegraphic transfer buying and selling rates or an approximate exchange rate with a variance not exceeding ±1%—quoted by the commercial bank with which the enterprise regularly conducts transactions.This exchange rate is used to recognise revenue and trade receivables and to account for foreign exchange differences.
2. Exchange rate for tax and customs purposes - the most significant change
Under Clause 4, Article 14 of Decree No. 252/2026/ND-CP, the exchange rate used for tax calculation must be determined in accordance with customs regulations rather than accounting regulations, as previously prescribed under Circular No. 80/2021/TT-BTC. Circular No. 80/2021/TT-BTC was repealed by Circular No. 89/2026/TT-BTC, effective from 1 July 2026.The relevant customs provision is Clause 5, Article 21 of Decree No. 08/2015/ND-CP, as amended and supplemented by Clause 9, Article 1 of Decree No. 167/2025/ND-CP. Accordingly, the exchange rate used for tax calculation is the foreign currency telegraphic transfer buying rate quoted by Vietcombank’s Head Office at the end of Thursday of the immediately preceding. Where that Thursday falls on a public holiday or non-working day, the rate quoted at the end of the immediately preceding working day applies.
For currencies for which no rate has been published, the applicable rate is determined using a cross exchange rate against currencies for which the State Bank of Vietnam has published exchange rates.
Key implication: The concurrent application of two exchange rates may result in differences among the revenue recorded in the accounting books, the amount stated on the export invoice and the amount declared to customs. Detailed guidance from the competent authorities is still pending.
3. Export invoices from 1 July 2026
- Under Article 8 of Decree No. 254/2026/ND-CP, invoices applicable to export activities include:
VAT invoices for taxpayers applying the credit method; - Sales invoices for taxpayers applying the direct method and for organisations and individuals operating in non-tariff zones;
- Electronic commercial invoices, provided that the conditions for transmitting electronic invoice data to the tax authority are satisfied; and
- Ex-warehouse delivery notes cum internal transport documents.
Under Clause 1, Article 9 of Decree No. 254/2026/ND-CP, the seller may determine the issuance date of an export invoice. However, the invoice must be issued no later than the next working day following the date on which the goods complete customs clearance.
💡 Immediate actions for enterprises
- Review revenue-recognition and customs-declaration procedures to identify and control differences among the accounting records, invoices and customs declarations.
- Ensure that import-export teams regularly update the exchange rate published by Vietcombank’s Head Office every Thursday.
- Closely monitor further detailed guidance from the competent authorities.
>>> Download Decree 252/2026/ND-CP
This newsletter has been prepared by Crowe Vietnam for general information and reference purposes only. It does not constitute legal, tax or accounting advice in relation to any specific circumstances. Laws and regulations may be amended or may no longer be in effect at the time this newsletter is accessed. Readers should consult the original legal instruments and seek advice from Crowe Vietnam’s professionals before applying the information to any particular situation. Crowe Vietnam accepts no responsibility for any loss arising from reliance on the information contained in this newsletter without obtaining appropriate professional advice.