Vietnam has officially postponed their clearance model-based e-invoicing from 1st November 2020 to 1st July 2022, which means that taxpayers will still have to stay in the transitional period. During this period, using both paper invoices and the new (or current) invoicing rules applies. 

However, the General Department of Taxation (GDT) strongly advises taxpayers to switch to e-invoicing either way before the deadline. For this reason, fiscal regulations have been released, mostly related to the governing technology and infrastructure-related details. 

The current paper-based system is naturally very vulnerable to fraud and needs immediate change. Moreover, it represents a great burden for taxpayers and tax authority – both financial and administrational. While some groups of taxpayers are advised to adopt the new e-invoicing system, others are obliged to implement e-invoicing before the deadline. The Vietnamese Government already issued some requirements which must be met for valid e-invoicing. 

Decree No. 119/2018/ND-CP is the one that goes deeper into the topic. It indicates the basic requirements of infrastructure in article 32, point 1 let. d). Here is what the equipment and the infrastructure must ensure: 

  • Uninterrupted provision of e-invoicing service – This includes ensuring a secure connection with the GDP’s server 
  • Data protection – must be able to detect and prevent illegal access and attacks on the network, as well as ensure confidentiality of the exchanged data. 
  • The procedures for data backup – which includes online data backup, data restore, and data recovery from the time of failure of the system. 
  • Storage of all electronic documents as well as their accessibility 
  • Connection standards of the Ministry of Finance must be met 

 The requirements above are crucial for service providers who wish to deliver the e-invoicing service in Vietnam. There are some additional conditions that the providers must fulfill in order to offer their services, e.g. prerequisites regarding the providers profile, finance, contract provisions, etc. 

The e-invoice format is based on the XML format. E-invoice consists of two parts; one part contains the data of the e-invoice and the other (clearance) data of the digital signature.  

The content of a Vietnamese e-invoice includes all the regular items included in the paper invoices, however, with the addition of some new data specific for the e-invoice, such as: 

  • The digital signature 
  • Time of issuing an e-invoice 
  • The Tax Authority’s code 
  • Fees and charges data 

According to Circular 68, in certain cases (sales in selected sectors) a waiver may be applied in terms of fiscalization requirements (e.g. supermarkets, shopping malls, the oil and gas sector, construction and installation, stamps, and tickers). 

 As far as corrections of an e-invoice go, some will demand re-issuing, while others won’t – it mostly depends on the type of the error and how critical it is. 

For example, if an e-invoice has the wrong address of a customer or the wrong address of the customer, then re-issuing isn’t necessary. The seller should simply inform both the customer and the Tax Authority about the mistake. However, if the error is related to the tax code, invoice amount rate, tax rate, tax amount or description of goods, then a new e-invoice must be issued. 

It is evident that Vietnam is very close to completely transforming its system from paper-based to e-invoicing considering all the adopted regulations and legal acts. However, most of the businesses weren’t ready to implement such a huge change in such a small time, which is considered to be the main reason for the postponement. 

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