Purchasing raw fish from fishing vessel owners: Supporting documents for deductible expenses

The Department of Taxation has responded to a petition from the Vietnam Federation of Commerce and Industry (VCCI) on difficulties faced by fish sauce producers when purchasing fish from fishing households and vessel owners. According to the Department of Taxation, current tax laws already address this issue. Purchasing enterprises need payment documents and a Purchase Statement signed by the enterprise itself; the seller is not required to sign the Purchase Statement.

Practical difficulties

Through Official Letter No. 1921/LDTM-PC of VCCI (summarizing enterprises' difficulties in August 2026), the Traditional Fish Sauce Association reported the following:

• Many fishing households and vessel owners are reluctant to sign confirmations of fish sales to fish sauce producers. They are concerned that if their sales exceed the threshold without invoices, they will have to pay tax.
• For this reason, they refuse to receive payments by bank transfer.
• Meanwhile, producers need grounds and documents to prove their purchases of raw materials.

The Association requested that tax authorities in localities with traditional fish sauce craft villages guide and support fishing vessels in confirming fish sales. The aim is to ensure that enterprises have complete records and documents as required.

1. Tax obligations of fishing households and vessel owners

According to the Department of Taxation, the obligations of household businesses and individual business persons to issue invoices, declare and pay tax are specifically provided in the following instruments:

• Law on Value-Added Tax 2024 (Law No. 48/2024/QH15)
• Law on Corporate Income Tax 2025 (Law No. 67/2025/QH15)
• Law on Personal Income Tax 2025 (Law No. 109/2025/QH15)
• Decree No. 68/2026/ND-CP dated 05 March 2026 on tax policies and tax administration for household businesses and individual business persons
• Their amending, supplementing and implementing documents

Fishing households and vessel owners shall base on the actual characteristics of their production and business activities to fulfil their tax obligations (if any) in accordance with the law.

2. Supporting documents for enterprises to deduct fish purchase expenses

The Department of Taxation refers to Point b, Clause 1, Article 9 of Decree No. 320/2025/ND-CP dated 15 December 2025. This provision sets out deductible expenses and the conditions for deduction when determining taxable income for corporate income tax (CIT) purposes, and applies to the following cases:

• Purchases of agricultural, forestry and aquatic products directly sold by producers or fishers.
• Purchases of goods and services from individuals or household businesses whose revenue is below the VAT-taxable revenue threshold. This group excludes purchases from fishers selling directly, as those already fall under the group above.

In these cases, the expense must be supported by two types of documents:

1. Payment documents to the seller in accordance with the laws on accounting, invoices and documents. Where the total value of purchases in a day from each household or individual is VND 5 million or more, the enterprise must make a non-cash payment.
2. A Purchase Statement of goods and services signed by the enterprise's legal representative or authorized person, who shall be responsible for it.

According to the Department of Taxation, the Purchase Statement does not require the seller's signature.

3. Conclusion of the Department of Taxation

The Department of Taxation considers that current tax laws already provide guidance on the issue raised by the Traditional Fish Sauce Association. It requested VCCI to continue coordinating with tax authorities in communicating with and guiding households, individuals, fishing vessel owners, and fish purchasing and fish sauce producing organizations to properly comply with regulations on tax, invoices and documents.

💡 Recommendations for enterprises

• Standardize the Purchase Statement. Prepare the Purchase Statement using the prescribed form, signed by the legal representative. If signed by another person, a clear letter of authorization is required.
• Monitor the VND 5 million threshold. Aggregate purchase values per day and per seller, rather than per individual purchase.
• Correctly identify the seller. For purchases through traders or wholesale collectors, enterprises should determine the seller's status, revenue level and the conditions for applying the Purchase Statement before preparing the supporting documents.
• Keep evidence of actual transactions. In addition to the Purchase Statement and payment documents, enterprises should retain weighing slips, delivery and receipt records, and seller identification details to support explanations during tax inspections.
• Communicate with vessel owners. Explain that they are not required to sign the Purchase Statement, and agree on a payment method consistent with the non-cash payment threshold.

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.