Circular 32/2025/TT-BTC (“Circular 32”) dated May 31st, 2025, issued by Ministry of Finance, provides guidance on some articles of Decree 70/2025/ND-CP (“Circular 70”) prescribing invoices, documents, which is effective from June 1st, 2025.
Authorization to issue e-invoices
Good sellers or service providers are allowed to authorize third parties(*) that are eligible to use e-invoices, and are not suspended from use of e-invoices to issue e-invoices for their sale of goods or provision of services.
(*) A third party affiliated with the goods seller/ service providers is not required.
Application of e-invoices in other specific cases
- Goods sold or services provided regularly and in large quantities, and needing time for data checking and verification to issue invoices, includes derivatives, industrial catering services, services provided by Mercantile Exchange of Vietnam, etc., for which invoices must be issued in accordance with Point a Clause 4 Article 9 of the Decree 123/2020/ND-CP (amended by Clause 6 Article 1 of the Decree 70).
- Financial leasing subject to value-added tax (VAT) must be supported by a VAT invoice for domestically purchased assets or by VAT payment documents for imported assets;
When invoices are issued, total VAT amount on output VAT invoices
must match
the VAT amount on input VAT invoices for the underlying assets (or proofs of VAT payment during importation), and "CTTC" must be written next to the tax rate.
Conversion to e-invoices
- If a taxpayer using unauthenticated e-invoices wants to use authenticated e-invoices, it shall follow procedures for modification of information about the use of e-invoice as prescribed in Article 15 of the Decree No. 123/2020/ND-CP (amended by clause 11 Article 1 of the Government’s Decree No. 70/2025/ND-CP dated March 20, 2025.
- Mandatory transition to authenticated e-Invoices for high-risk taxpayers. Taxpayers classified as high-risk in accordance with regulations are required to switch to using authenticated e-invoices issued by the tax authority.
- Accordingly, within ten (10) working days from the date of notification by the tax authority, the taxpayer must update their e-invoice usage information (from unauthenticated e-invoices to authenticated e-invoices issued by Tax authority).
After 12 months, if the taxpayer wishes to revert to using unauthenticated e-invoices, they may apply for the change; however, approval is subject to review and discretion of the tax authority on a case-by-case basis.
- In case enterprises do multiple business activities:
Using of e-invoices generated by POS cash registers: for sale of goods or provision of services to/for consumers (shopping malls; supermarkets; retailers (except automobiles, motorcycles, motorbikes and other motor vehicles), etc.
Using of authenticated or unauthenticated e-invoices: for other business activities, not included in businesses using e-invoice generated by POS cash registers.
Criteria for identification of taxpayers posing high tax risks upon application for use of e-invoices
- Article 9, Circular 32/2025/TT-BTC prescribes 05 criteria to identify high tax risks upon application for use of e-invoices.
Besides, in order to meet tax administration requirements in each period, the Tax Department is assigned to issue regulations on criteria to assess and identify taxpayers found to pose very high tax risks on the basis of assessment of taxpayers when performing tax administration tasks.