Vietnam: Regulations on the simultaneous use of paper invoices and e-invoices

Vietnam’s current regulations require all businesses to use e-invoices from November 01, 2020. Before this date, businesses could use both paper invoices and e-invoices. The specific instructions are as follows.

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According to Clause 3 Article 7 of Circular No. 32/2011/TT-BTC of the Ministry of Finance of Vietnam:

“A business may concurrently create different forms of invoices (self-printed invoices, invoices printed on order, e-invoices) and shall make an issuance notice for each form of invoices under regulations.

For each time of selling goods or providing services, a business may use only one (1) form of invoices. Specifically, if it uses a self-printed invoice for sale of goods or provision of services, it may not use an invoice printed on order or an e-invoice for such sale or provision. If it uses an e-invoice, it may not use a self-printed invoice or an invoice printed on order. If it uses an invoice printed on order, it may not use an e-invoice or a self-printed invoice.”

According to the above regulations, enterprises may concurrently create different forms of invoices (self-printed invoices, invoices printed on order, e-invoices) and must notify the issuance of each form of invoice according to regulations. However, for each sale of goods or provision of services, the company only uses one form of invoice.

The notification of issuance of e-invoices shall be carried out in accordance with regulations of Article 7 of Circular No. 32/2011/TT-BTC guiding the creation and issuance of e-invoices for sale of goods and provision of services.

With regard to conversion of e-invoices into paper ones, pursuant to Article 12 of Circular No. 32/2011/TT-BTC and Article 19 of Circular No. 39/2014/TT-BTC, if the business establishment is allowed to use self-printed invoices, invoices are issued and printed by the software, and the quantity of goods and services sold is greater than the number of lines of an invoice, the Provincial Department of Taxation shall consider allowing the business establishment to use an invoice that consist of more than one page, on a case-by-case basis, if the invoice number (generated by computers), name, address, and TIN of the buyer, the same template number and  invoice symbol on the top of the next pages are the same as those on the first page, and the text “tiep theo trang truoc – trang X/Y” (continued from previous invoice - page X/Y). X is the current page, Y is the total number of pages of the invoice).

Time of application of e-invoices to know (according to Decree No. 119/2018/ND-CP of Vietnam’s Government):

Before November 01, 2018:

- Enterprises and economic organizations that have informed the issue of unauthenticated e-invoices or have registered the use of authenticated e-invoices before November 01, 2018 shall be allowed to continue to use existing e-invoices.

- Enterprises that have informed the issue of paper invoices or have purchased invoices issued by the tax authority for use before November 01, 2018 shall be entitled to continue to use these invoices until end of October 31, 2020 and follow invoice-related procedures as provided in Decree No. 51/2010/ND-CP and Decree No. 04/2014/ND-CP of Vietnam’s Government. If all paper invoices are used before November 01, 2020, they will be transferred to e-invoices and no paper invoices will be printed.

From November 01, 2018 to October 31, 2020: With respect to businesses newly established during the period from November 01, 2018, if the tax authority informs businesses of implementing e-invoices, these businesses must follow the tax authority’s instructions. If the business fails to meet information technology infrastructure requirements and continue to use the aforesaid invoices, it must send its invoice data to the tax authority by using the Form No. 03 hereto appended and submit its VAT declaration.

By November 01, 2020: Businesses shall complete the organization of implementing e-invoices and authenticated e-invoices in accordance with Decree No. 119/2018/ND-CP.

Duy Thinh

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