On June 3rd, 2022, the General Department of Customs issued Official Letter No. 2054/TCHQ-GSQL on the use of e-invoice for exported goods. As follows:
1. Regulations on invoices in export customs dossiers
According to international practice, when carrying out export procedures, enterprises use commercial invoices to carry out customs procedures and export goods to foreign countries. According to the provisions of Article 24 of the Customs Law and the provisions of Point b, Clause 1, Article 16 of Circular No. 38/2015/TT-BTC dated March 25th, 2015 as amended and supplemented in Clause 5, Article 1 of Circular No. 39 /2018/TT-BTC dated April 20th, 2018 of the Ministry of Finance, the customs dossier for exported goods includes commercial invoices or equivalent documents if the buyer has to pay the seller, there is no requirement to issue additional electronic VAT invoices to carry out export procedures.
2. Invoicing time for export goods is according to the provisions of Decree 123/2020/ND-CP dated October 19th, 2020.
According to the provisions at Points b and c, Clause 3, Article 13 of this Decree, after the export procedures are completed, the exporter shall issue a VAT invoice for the exports. Therefore, at the time of carrying out customs procedures for exported goods, the exporter has not yet been able to issue a VAT invoice for submission in the customs dossier.
3. Thus, e-invoices are made according to Vietnamese law, and invoices in international trade comply with international practices. The time of issuance of these two types of invoices is different: commercial invoices are issued before customs procedures and e-invoices are issued later.