On November 25, 2025, the Tax Department issued Official Letter No. 5487/CT-CS providing guidance on value-added tax (VAT) policies for deferred or installment payments of goods and services valued at VND 5 million or more, in cases where non-cash payment vouchers are not available at the payment due date.
1. Key Points of the Official Letter for VAT Deductibility for delayed payments
1.1. Legal Basis
- Clause 2, Article 14 of the Law on Value-Added Tax No. 48/2024/QH15 dated November 26, 2024.
- According to Article 25 of Decree No. 181/2025/NĐ-CP dated July 1, 2025 of the Government on invoices and documents for tax payment.
- According to Article 26 of Decree No. 181/2025/NĐ-CP dated July 1, 2025 of the Government on non-cash payment documents.
1.2. Principles for Deducting Input VAT in Cases of Deferred or Installment Payments
For goods and services worth VND 5 million or more, when payment is made on a deferred or installment basis, if the enterprise fails to provide non-cash payment documents by the due date specified in the contract or its addendum, it is required to:
- The enterprise must declare and adjust to reduce the deductible input VAT for the portion of goods or services that does not have valid non-cash payment documents.
- This adjustment must be carried out in the tax period in which the payment obligation arises under the contract or contract addendum.
In cases where, after making the downward adjustment, the enterprise is able to provide the required non-cash payment documents,
- The enterprise may subsequently declare and reclaim the input VAT deduction for those goods and services once the required non-cash payment documents have been provided in accordance with regulations.
See the full official letter at: VAT deductibility for delayed payments
2. Types of Non-Cash Payment Methods in Decree No. 181/2025/NĐ-CP
Non-cash payment methods, as prescribed in Article 26 of Decree 181/2025/NĐ-CP, include:
| No. | Non-cash payment methods | Required documents |
|
1 |
Bank transfer | A bank transfer slip is required; cash deposit receipts into the seller’s account are not accepted. |
|
2 |
Offsetting liabilities arising from the purchase and sale of goods or services | A contract specifying the offsetting method and a reconciliation statement between the parties are required. |
|
3 |
Debt settlement via loan/borrowed funds | There must be a written loan/borrowing agreement established in advance, along with bank transfer documents from the lender’s account to the borrower’s account. |
|
4 |
Payment through a third party by authorization | It must be clearly specified in the written contract, and the authorized recipient/third party must be an organization or individual operating legally. |
|
5 |
Payment by shares or bonds | There must be a written transfer agreement signed prior to the payment date. |
|
6 |
In cases where the remaining payment, made through multiple methods, totals from VND 5 million or more | The remaining amount must be supported by valid non-cash payment documents. |
|
7 |
Payment into a Compulsory Account at the State Treasury | In cases of tax enforcement, payment is made into a third-party account designated by the government authority. |
|
8 |
Deferred or installment payment | The sales contract must be accompanied by the invoice and proof of payment when the payment becomes due. |
|
9 |
For purchases or import values under VND 5 million per transaction, or for gifts and donations | Non-cash payment documents are not required |
|
10 |
Authorization for employees/individuals to make payment | Financial or internal regulations + reimbursement documents for employees. |
|
11 |
Multiple purchases within the same day with a total value of VND 5 million or more | Input VAT is deductible only when supported by valid non-cash payment documents. |
Vina TPT Tax Services is ready to support your business with accurate VAT review, input tax deduction assessment, compliant documentation checks, and timely declarations. Contact Vina TPT for expert guidance and end-to-end tax compliance support tailored to your enterprise.
