01:51 | 17/10/2022

Instruction on issuance of e-invoices for companies that sell goods and provide services in free trade zones in Vietnam?

Instruction on issuance of e-invoices for companies that sell goods and provide services in free trade zones in Vietnam? - Question of Ms. Thuy from Vung Tau

If a company is an enterprise in a free trade zone that sell goods or provide services, do its invoices need to bear the phrase "For organizations/individuals in free trade zones"?

According to Clauses 1 and 2, Article 8 of Decree No. 123/2020/ND-CP, the invoice types in Vietnam are as follows:

Invoice types in Vietnam
Invoices prescribed herein are classified into the following types:
1. Value-added tax (VAT) invoice is an invoice which may be used by organizations making VAT declaration by employing the credit-invoice method for the following activities:
a) Domestic sale of goods or provision of services;
b) Provision of international transport services;
c) Export of goods to free trade zones and other cases considered as export of goods;
d) Export of goods or provision of services in a foreign market.
2. Sales invoice is an invoice which may be used by the following organizations and individuals:
a) Organizations or individuals that declare and calculate VAT by employing direct method for the following activities:
- Domestic sale of goods or provision of services;
- Provision of international transport services;
- Export of goods to free trade zones and other cases considered as export of goods;
- Export of goods or provision of services in a foreign market.
b) Organizations or individuals in free trade zones that sell goods or provide services to the domestic market, sell goods or provide services to other organizations/individuals in free trade zones, or sell goods or provide services to a foreign market. In such cases, invoices must bear the phrase “Dành cho tổ chức, cá nhân trong khu phi thuế quan” ("For organizations/individuals in free trade zones”).

Thus, organizations or individuals in free trade zones that sell goods or provide services to the domestic market, sell goods or provide services to other organizations/individuals in free trade zones, or sell goods or provide services to a foreign market. In such cases, invoices must bear the phrase “Dành cho tổ chức, cá nhân trong khu phi thuế quan” ("For organizations/individuals in free trade zones”).

Instruction on issuance of e-invoices for companies that sell goods and provide services in free trade zones in Vietnam?

Instruction on issuance of e-invoices for companies that sell goods and provide services in free trade zones in Vietnam? (Image from the Internet)

Is a company in a free trade zone required to use invoices in sale of goods and provision of services?

Pursuant to Point c, Clause 3, Article 13 of Decree No. 123/2020/ND-CP stipulating the use of e-invoices in sale of goods and provision of services as follows:

Use of e-invoices in sale of goods and provision of services
3. Application of e-invoices, delivery and internal transfer notes, and delivery notes for goods sent to sales agents in some cases:
c) Use of electronic VAT invoices by exporters declaring and paying VAT by following credit-invoice method (including export processors):
When delivering goods to the border checkpoint or customs post where export procedures are followed, the exporter shall use the delivery and internal transfer note as document for goods circulation. After the export procedures are completed, the exporter shall issue a VAT invoice for the exports.

Official Dispatch No. 7396/CTTPHCM-TTHT in 2022 guides as follows:

Pursuant to the above provisions, the company is an enterprise in a free trade zone, it may use invoices in sale of goods and provision of services to the inland and in sale of goods and provision of services between organizations and individuals in free trade zones, exporting goods, providing services abroad.

Instruction on issuance of e-invoices for companies in free trade zones in Vietnam?

Pursuant to the provisions at Points a and b, Clause 1, Article 4 of Circular No. 78/2021/TT-BTC, the form number, reference number and names of copies of an invoice are prescribed as follows:

Form number, reference number and names of copies of an invoice
1. E-invoices
a) Form number of an e-invoice is a digit from 1 to 6 depending on the type of e-invoice:
- 1: Electronic VAT invoice;
- 2: Electronic sales invoice;
- 3: E-invoice for sale of public property;
- 4: E-invoice for sale of national reserve goods;
- 5: Other types of e-invoice, including electronic stamp, ticket, card, receipt or other electronic documents that have other names but have the same contents as an e-invoice as prescribed in the Decree No. 123/2020/ND-CP;
- 6: Electronic records which are used and managed in the same manner as invoices, including electronic delivery and internal consignment notes, and electronic delivery notes for goods sent to sales agents.
b) Reference number of an e-invoice contains 6 characters, including letters and numbers, indicating whether the invoice bears the tax authority’s identification code or not, year of issuance, and type of e-invoice. 6 characters are as follows:
- The first character: C if the invoice bears a tax authority’s authentication code; K if the invoice does not bear a tax authority’s authentication code;
- The next two characters are the last two digits of the year in which the e-invoice is issued, written in Arabic numerals. Example: 22 if the e-invoice is issued in 2022; 23 if the e-invoice is issued in 2023;
- The next character is either T, D, L, M, N, B, G or H depending on the type of e-invoice. To be specific:
+ T: E-invoices registered with tax authorities by enterprises, organizations or household businesses;
+ D: E-invoices used for sale of public property or national reserve goods or special e-invoices that do not have some mandatory contents of the “T” invoices;
+ L: E-invoices issued separately by tax authorities;
+ M: E-invoices generated by cash registers;
+ N: Electronic delivery and internal consignment notes;
+ B: Electronic delivery notes for goods sent to sales agents;
+ G: VAT invoices in the form of electronic stamps, tickets or cards;
+ H: Sales invoices in the form of electronic stamps, tickets or cards.
- The last two characters shall be decided by the seller to serve their management requirements. If the seller uses different forms of the same type of e-invoice, the last two characters shall be used to differentiate such e-invoice forms. If the seller does not decide the last two characters, YY shall be specified;
- The reference number and form number of an e-invoice shall be written on the upper right corner of the invoice (or a noticeable position);
...

In Official Dispatch No. 7396/CTTPHCM-TTHT in 2022, Ho Chi Minh City Tax Department guides as follows:

Based on the above provisions, when the Company in a free trade zone exports goods, it will have to issue an electronic invoice that bears a tax authority’s authentication code in the correct format and symbol specified in Circular No. 78/2021/TT-BTC after completing procedures for exports.

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