E-invoices Are Not Required to Contain All Details

Full text of the latest guidelines on electronic invoices

1. Regarding the criterion of the buyer's electronic signature on the electronic invoice

Pursuant to Clause 2, Article 6 of Circular 32/2011/TT-BTC which stipulates "In some cases, electronic invoices do not have all the mandatory contents, to be implemented according to the separate guidance of the Ministry of Finance".

At the same time, the Ministry of Finance has issued Official Dispatch 2402/BTC-TCT guiding the implementation of electronic invoices as follows:

"In case the buyer is not an accounting unit or is an accounting unit but has documents and vouchers proving the provision of goods and services between the seller and the buyer, such as: economic contracts, delivery notes, goods acceptance records, payment receipts, collection vouchers, etc., the seller should create an electronic invoice for the buyer as prescribed. The electronic invoice does not necessarily have to have the buyer’s electronic signature."

2. Regarding the criterion of the seller's seal on the electronic invoice converted to paper

According to Clause 1, Article 12 of Circular 32/2011/TT-BTC, regulations on the principle of converting electronic invoices to paper invoices are as follows:

"1. Principles of conversion

The seller of goods is allowed to convert electronic invoices to paper invoices to prove the origin of tangible goods in circulation and is only allowed to convert once (01) time. Electronic invoices converted to paper invoices to prove the origin of goods must meet the regulations set out in Clauses 2, 3, and 4 of this Article and must have the representative’s signature according to the law, and the seller's seal.

..."

However, pursuant to Clause 2b, Article 5 of Circular 119/2014/TT-BTC, which amends Point a, Clause 3, Article 4 of Circular 39/2014/TT-BTC, it is stipulated:

"a) Business organizations selling goods or services may create, issue, and use invoices without necessarily having the buyer's signature or the seller's seal in the following cases: electricity invoices, water invoices, telecommunication service invoices, banking service invoices meeting the self-printed conditions as guided in this Circular.

In case of providing services, the invoice does not necessarily have the criterion "unit of measure."

Thus, the conversion of electronic invoices to paper invoices must comply with the principle in Clause 1, Article 12 of Circular 32/2011/TT-BTC and if falling under the cases prescribed in Clause 2b, Article 5 of Circular 119/2014/TT-BTC, the electronic invoice converted to paper does not necessarily have the seller's seal.

See detailed guidance content in Official Dispatch 2296/TCT-DNL issued on June 6, 2019.

Duy Thinh

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