Product samples for product introduction: how should costs be recognised and invoices issued?

In response to an enquiry from a cosmetics manufacturer, the Tay Ninh Provincial Tax Authority provided guidance on the accounting treatment, Corporate Income Tax (CIT), invoicing and Value Added Tax (VAT) treatment applicable to raw materials and products used as samples for introduction to customers. The Official Letter refers concurrently to four new legal documents effective during 2025–2026, making these important references for enterprises that distribute product samples.

1. Recognition of costs for raw materials used as samples: under Circular No. 99/2025/TT-BTC

From an accounting perspective, enterprises shall account for these transactions in accordance with Article 11 of Circular No. 99/2025/TT-BTC dated 27 October 2025 (enterprise accounting regime). Accordingly:

• Enterprises shall apply the chart of accounts set out in Appendix II issued together with the Circular (Clause 1, Article 11).
• Enterprises may amend or supplement account names, account numbers, structures and accounting contents to suit their operational characteristics, provided that such changes do not alter or affect items presented in the financial statements. Where amendments are made, the enterprise must issue internal Accounting Regulations (or an equivalent document) clearly stating the necessity for the changes and the enterprise's responsibilities (Clause 2, Article 11).
• For transactions not specifically addressed by the Circular, enterprises shall apply the substance of the transaction, the Law on Accounting, guiding documents under the Law on Accounting, Vietnamese Accounting Standards and the principles prescribed in this Circular (Clause 3, Article 11).

2. Deductible expenses for CIT purposes: a report on the investment policy is required

Expenses for introducing/marketing products and services before sales commence are deductible for CIT purposes under Point i6, Clause 2, Article 9 of Decree No. 320/2025/ND-CP dated 15 December 2025, provided that the enterprise has a report on the investment policy for the production of products and services submitted to the relevant state authority in accordance with specialised legislation. Where specialised legislation does not require such report to be submitted, the enterprise shall retain the report at its premises.

Regarding supporting documentation, Point e, Clause 9, Article 3 of Circular No. 20/2026/TT-BTC dated 12 March 2026 (guiding the 2025 Law on Corporate Income Tax and Decree No. 320/2025/ND-CP) provides that the supporting documentation for this expense consists of the very report on the investment policy referred to in Point i6, Clause 2, Article 9 of Decree No. 320/2025/ND-CP.

3. E-invoicing: invoices must still be issued for product samples

Under Clause 1, Article 4 of Decree No. 254/2026/ND-CP dated 30 June 2026 on electronic invoices and documents, when selling goods or providing services, the seller must issue an e-invoice to the buyer, including goods and services used for sales promotion or advertising, product samples; goods given away, donated, gifted or exchanged, goods given in lieu of salary or used for internal consumption; and goods released on loan or lent out, except for cases where e-invoices are not required under Article 7 of the Decree. The invoice must comply with the prescribed standard data format and contain all information required under tax and accounting regulations and Article 10 of Decree No. 254/2026/ND-CP. The seller is responsible for the accuracy of the invoice issued.

4. VAT taxable price for product samples: zero where the sales promotion complies with commercial law

Clause 2, Article 6 of Decree No. 181/2025/ND-CP dated 1 July 2025 (providing detailed regulations for the Law on VAT) stipulates that goods and services used for sales promotion in accordance with commercial law have a VAT taxable price of zero (0). For discount promotions, however, the taxable price is the discounted price that has been registered/notified. Specific forms for which the taxable price is zero or the value of promotional goods is excluded from the taxable price include:

• Providing sample goods or sample services for customers to try free of charge → VAT taxable price is zero (Point a);
• Giving goods or services free of charge → VAT taxable price is zero (Point b);
• Sales accompanied by purchase vouchers/service vouchers; contest entry forms; promotional programmes of chance; customer loyalty programmes → the taxable price excludes the value of vouchers, prizes, customer cards, etc. (Points c, d, dd and e).

Important note: where the above forms are implemented but do not comply with the sales promotion requirements under commercial law, the taxable price shall be determined in the same manner as for goods given away, donated or gifted under Clause 1, Article 6 of Decree No. 181/2025/ND-CP (final paragraph of Clause 2, Article 6).

💡 Recommendations for enterprises

1. Review and fully retain the report on the investment policy for product production as supporting documentation for deductible expenses relating to samples used to introduce new products.
2. Issue e-invoices for every batch of product samples delivered to customers, and do not omit invoicing on the basis that the samples are provided "free of charge".
3. Submit sales promotion notifications to all Departments of Industry and Trade in the localities where the promotion is organised, at least 3 working days before distributing product samples, in order to qualify for a VAT taxable price of zero.
4. If accounting accounts are amended to track product samples, issue internal Accounting Regulations in accordance with Clause 2, Article 11 of Circular No. 99/2025/TT-BTC.

>>> Download Official Dispatch 6927/TNI-QLDN2

This newsletter has been prepared by Crowe Vietnam for general information purposes only and is not a substitute for advice on any specific case. Enterprises should refer to the original legal documents and consult professional advisers before applying the guidance to their particular circumstances.