International transport support services abroad: Outside the scope of VAT, but invoices must still be issued

On 14 October 2026, the Tax Department issued Official Letter No. 7634/CT-QLNT in response to Viettel Logistics One Member Limited Liability Company (Letter No. 649/LOG-TC dated 12 August 2026). The letter addresses value-added tax (VAT) and invoicing for international transport support services performed abroad.

The letter reaches two conclusions. First, these services fall outside the scope of the VAT Law. Second, the provider must still issue invoices to the buyer. This is relevant to logistics and freight forwarding companies that provide services abroad to Vietnamese customers.

1. VAT: outside the scope of the VAT Law

Under Article 3 of the Law on Value-Added Tax No. 48/2024/QH15 dated 26 November 2024, goods and services subject to VAT are those used for production, business and consumption in Vietnam.

The case reviewed by the Tax Department: a company provides Vietnamese enterprises with international transport support services, namely cargo handling, customs clearance, loading and unloading, lifting, and packing.

The Tax Department's conclusion depends on two conditions:

• the services are not performed in Vietnam, and
• the services are not used for production, business or consumption in Vietnam.

Where both conditions are met, the services fall outside the scope of the VAT Law (Article 3 of Law No. 48/2024/QH15).

📌 Additional note from Crowe Vietnam

Beyond the contents of the Official Letter, enterprises should distinguish international transport support services from international transport services. Under the regulations, international transport does not fall outside the scope of the VAT Law in the way described above. It belongs to the group of other exported goods and services that qualify for the 0% VAT rate (Point c, Clause 1, Article 9 of Law No. 48/2024/QH15).

• Scope: international transport covers the carriage of passengers, luggage and goods on international routes, i.e. from Vietnam to a foreign country, from a foreign country to Vietnam, or between two points outside Vietnam. The provider does not need to operate the means of transport itself (Point a, Clause 3, Article 17 of Decree No. 181/2025/ND-CP).
• Conditions for the 0% rate: a contract for carriage on an international route and evidence of non-cash payment (Clause 3, Article 18 of Decree No. 181/2025/ND-CP).

In short, support services performed entirely abroad fall outside the scope of the VAT Law. The international transport leg itself remains subject to VAT, at the 0% rate if all conditions are met.

2. Invoicing: still required

As a general principle, organizations and individuals selling goods or providing services must issue invoices to buyers. The legal basis is Clause 1, Article 4 of Decree No. 254/2026/ND-CP dated 30 June 2026 on the principles for issuing, managing and using electronic invoices and documents.

Accordingly, even where the services are performed (take place) abroad, the provider must still issue invoices to the buyer under Clause 1, Article 4 of Decree No. 254/2026/ND-CP.

The Tax Department requests that the company rely on the above regulations and its actual circumstances to comply.

💡 Recommendations for enterprises

• Identify where each service is performed and where it is consumed. The "outside the scope" conclusion applies only where a service is neither performed in Vietnam nor used for production, business or consumption in Vietnam.
• Separate, in contracts and invoices, the services performed abroad from those performed in Vietnam, as the latter may still be subject to VAT.
• Keep supporting documents proving that the services took place abroad, such as documents from overseas agents or partners and service completion records.
• Do not overlook invoicing for services that fall outside the scope of the VAT Law.
• This official letter responds to a specific company. Where your circumstances differ, consult your directly managing tax authority.

This newsletter is prepared by Crowe Vietnam for general information purposes only and does not constitute advice for any specific case. Enterprises should refer to the original legal instruments and consult professional advisors before applying the above to their particular circumstances.