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SOME KEY UPDATES IN CIRCULAR NO. 32/2025/TT-BTC PROVIDING GUIDELINES ON INVOICES AND DOCUMENTS
AS REGULATED BY THE LAW ON TAX ADMINISTRATION, DECREE NO. 123/2020/ND-CP, AND DECREE NO. 70/2025/ND-CP

On May 31, 2025, the Ministry of Finance issued Circular No. 32/2025/TT-BTC, providing guidance on the implementation of certain provisions of the Law on Tax Administration, Decree No. 123/2020/ND-CP, and Decree No. 70/2025/ND-CP. This circular takes effect from June 1, 2025. Some notable new points are as follows:

1/ Expanding the authorization rights for electronic invoicing

Business households and individual businesses are authorized to issue invoices through a third party without requiring the third party receiving the authorization to have an affiliated relationship with the seller. This authorization must be documented, established through a contract, and reported to the tax authorities.

2/ Addition of regulations on form codes and invoice symbols

2.1/ Addition of electronic invoice form codes number 7, 8, and 9 to reflect types of electronic invoices as follows:

Number 7: Reflects e-commerce invoices.

Number 8: Reflects value-added tax (VAT) invoices integrated with receipts for taxes, fees, and charges.

Number 9: Reflects sales invoices integrated with receipts for taxes, fees, and charges.

2.2/ Addition of characters indicating the type of e-commerce invoice used as follows:

Letter X: Applied to e-commerce invoices.

3/ Application of electronic invoices for special cases

  • Other cases subject to regulations on the timing of invoice issuance for the sale of goods or the provision of services in large quantities, occurring frequently, and requiring time for data reconciliation include:

+ Derivative products

+ Industrial catering services

+ Services of commodity exchange centers

  • Guidelines for issuing invoices for financial leasing activitie

 4/ VAT Invoice cum Tax Refund Declaration Form

The contents of the value-added tax (VAT) invoice cum tax refund declaration consist of three parts:

  • Part A: Prepared by the tax-refunding seller enterprise when selling goods.
  • Part B: Prepared by the customs authority to record the results of verifying the VAT invoice cum tax refund declaration, the goods, and calculate the VAT refundable to the foreign individual.
  • Part C: Prepared by the commercial bank acting as the tax refund agent.

↪  This is a new template introduced for the first time in Circular No. 32/2025/TT-BTC.

5/ Business activities subject to the use of electronic invoices generated from cash registers

  • In cases where an enterprise engages in multiple business activities, it shall register to use electronic invoices generated from cash registers for the following activities:
    • Sale of goods and provision of services directly to consumers (shopping centers; supermarkets; retail activities excluding automobiles, motorbikes, motorcycles, and other motor vehicles);
    • Food and beverage services; restaurants; hotels;
    • Passenger transportation services, services directly supporting road transport, arts, entertainment and recreational services, cinema operations, and other personal services as defined under the Vietnam Standard Industrial Classification;
    • The enterprise shall register to use e-invoices with tax authority codes or e-invoices without tax authority codes for its other business activities.

6/ Criteria for identifying high tax risk in electronic invoice registration

For the first time, the Ministry of Finance has issued criteria to identify taxpayers at high risk of tax-related issues when registering to use electronic invoices:

  • Criterion 1: The taxpayer has an owner or legal representative, household business representative, business individual, or private enterprise owner who simultaneously holds a similar position in other entities that have been concluded by competent state authorities to be involved in invoice fraud or trading, based on tax authority databases.
  • Criterion 2: The taxpayer has an owner or legal representative, household business representative, business individual, or private enterprise owner listed among entities with suspicious transactions under the Anti-Money Laundering Law.
  • Criterion 3: The taxpayer’s registered head office address lacks a specific location under administrative boundaries or is located in an apartment building (excluding those legally permitted for business use); or the business location lies outside the province/city where the head office or branch is based.
  • Criterion 4: The taxpayer’s legal representative or owner concurrently serves as the legal representative or owner of another taxpayer categorized as “Ceased operation without completing tax code termination” or “Not operating at registered address.” The taxpayer also exhibits violations relating to taxes, invoices, or documents as guided by the Minister of Finance.
  • Criterion 5: Other risk indicators identified by the tax authority, with formal notification and request for explanation sent to the taxpayer

7/ Guidance on the use of personal income tax withholding certificates from June 1, 2025

As of June 1, 2025, organizations responsible for withholding personal income tax must cease using electronic personal income tax withholding certificates issued under previous regulations and transition to using electronic personal income tax withholding certificates in accordance with the provisions of Decree No. 70/2025/NĐ-CP.

8/ Cases where use of cash register-generated e-invoices is not mandatory

According to Clause 5, Article 12 of Circular No. 32, enterprises that registered to use electronic invoices with or without tax authority codes for activities involving the direct sale of goods and provision of services to consumers (e.g., shopping centers, supermarkets, restaurants, hotels, passenger transportation, entertainment services, etc.) before June 1, 2025 may choose to:

  • Either switch to using electronic invoices generated from cash registers as stipulated in Decree No. 70/2025/NĐ-CP
  • Or continue using the e-invoices previously registered with the tax authority

9/ Guidance on handling incorrectly issued invoices before June 1, 2025

From the time businesses, organizations, households, or individuals begin using electronic invoices in accordance with Decree No. 123/2020/NĐ-CP (as amended and supplemented by Decree No. 70/2025/NĐ-CP) and this Circular, if an invoice issued under Decree No. 51/2010/NĐ-CP dated May 14, 2010, Decree No. 04/2014/NĐ-CP dated January 17, 2014, and relevant Ministry of Finance guidelines is found to contain errors:

  • The seller and buyer must prepare a written agreement clearly stating the errors and issue a new electronic invoice (with or without a tax authority code) to replace the incorrect one.
  • The replacement e-invoice must include the line: “Replacing invoice Form No… symbol… No… dated… month… year.”
  • The seller must digitally sign the new e-invoice to send to the buyer (if using an e-invoice without a tax authority code), or submit it to the tax authority for code issuance (if using an e-invoice with a tax authority code).