📌 Summary:
| Case | Non-cash payment methods | Documentation requirements |
|---|---|---|
| Usually, common, normal | Bank transfer (according to Decree 52/2024/ND-CP) |
Bank transfer documents. Cash payments into the seller's account are not accepted. |
| Feature 1 | Offsetting the value between goods and services |
Minutes of data reconciliation and confirmation between the two parties. If going through a third party, it is necessary A three-party debt offsetting agreement. |
| Feature 2 | Offsetting debts and loans. | Written loan/borrowing agreement established previously; money transfer documents from the lender's account to the borrower's account. |
| Feature 3 | Authorized third-party payment |
Specific regulations in written contract. The third party must be a legally operating organization/individual. |
| Feature 4 | Payment by stocks and bonds | Written sales contract established previously. |
| Feature 5 | Enforcement according to the State Decision | Money transfer documents into a third-party account at the State Treasury according to a decision of a state agency. |
| Feature 6 | Buy on credit, buy in installments |
Sales contract, VAT invoice, payment voucher. (If payment is due), if not yet due, a temporary deduction is still permitted. |
| Feature 7 | For imports under 05 million VND, and for goods imported as gifts or samples, payment is not required. | No non-cash payment documents are required for purchased goods and services. |
| Feature 8 | Employee-authorized payment |
Payment by cashless payment method. when authorizing payment on behalf of another party according to financial/internal regulations and refund procedures.
|
In the context of increasingly stringent regulations on VAT deductions regarding documentation and payment methods, establishing and properly storing non-cash payment documents has become a prerequisite for businesses to be eligible for VAT deductions. Current regulations require businesses to demonstrate the flow of payments through legitimate channels to be eligible for input VAT deductions. This article guides you through 10 cases and the documentation requirements for determining VAT deductions based on these regulations. Decree 181/2025/ND-CP October 01, 07.
I. What is cashless payment?
From January 01, 07, Law on Value Added Tax 2024 No. 48/2024/QH15 Officially in effect, the regulations detail the conditions for deducting input value-added tax. Specifically, Point b, Clause 2, Article 14 regulations:
"Non-cash payment documents are required for purchased goods and services, except in certain specific cases as stipulated by the Government;"
To provide specific guidance on this regulation, the Government issued the following on July 1, 2025. Decree 181/2025/ND-CP Guidelines on the Value Added Tax Law. In which, Article 26 Item 2 Decree regulating invoices for goods and services purchased on a case-by-case basis. from 05 million VND or more (VAT included) Non-cash payment documentation is required. to be eligible for input VAT deduction.
💡 The regulation on the minimum invoice value of 20 million VND in the amended Value Added Tax Law of 2013 has been abolished.
According to the Clause 1, Article 26 of Decree 181/2025/ND-CP:
Non-cash payment documents are Documents proving non-cash payment as stipulated in Decree No. 52/2024/ND-CP Government Decree dated May 15, 2024, on cashless payments. excluding payment receipts from the buyer. The money will be deposited into the seller's account.
⚠️ Note: Not accepted Documents showing the buyer depositing cash directly into the seller's account.
Decree No. 52 / 2024 / ND-CP Government Decree No. 15/5/2024 on non-cash payments stipulates: Non-cash payment methods (hereinafter referred to as payment methods) are means issued by payment service providers, financial companies authorized to issue credit cards, and payment intermediary service providers providing e-wallet services, and used by customers to conduct payment transactions, including: check, payment order, payment authorization, collection order, collection authorization, bank card (including: debit cards, credit cards, prepaid cards) electronic wallet and other means of payment as prescribed by the State Bank of Vietnam.
II. 08 Special Cases and Specific Document Requirements
According to the Point 2, Article 26 Decree 181/2025/ND-CP stipulates 08 special cases According to point b, clause 2, Article 14 of the Value Added Tax Law, the following are eligible for VAT deduction:
1. Settlement of value between goods and services.
In cases where goods and services are purchased through a clearing method between the value of purchased goods and services and the value of sold goods and services, or through borrowing, and this payment method is specifically stipulated in the contract, then the following must be provided: Minutes of data reconciliation and confirmation between the two parties regarding the clearing and settlement. Between goods and services purchased and goods and services sold, and goods borrowed. In cases of offsetting debts through a third party, there must be... Three-party debt offsetting agreement as a basis for tax deduction.
2. Offsetting loan and borrowing debts; offsetting through a third party.
In cases where goods and services are purchased through debt offsetting methods such as borrowing or lending money, or offsetting debts through a third party, and this payment method is specifically stipulated in the contract, then the following must be provided: loan agreements in written form that were drawn up beforehand. and have Documents for transferring money from the lender's account to the borrower's account. Regarding loans, borrowing in cash includes cases where the value of purchased goods or services is offset against the amount of money that the seller provides to the buyer, or that the buyer pays on their behalf.
3. Payment authorized through a third party.
In cases where goods and services are paid for through a third party using non-cash payment methods (including cases where the seller requests the buyer to make non-cash payment to a third party designated by the seller), the payment by authorization or payment to the third party as designated by the seller must be specifically stipulated in the contract. contract in written form and the third party is one an organization or individual operating in accordance with the law..
4. Payment by stock or bond
In cases where goods or services are purchased and payment is made in shares or bonds, and this payment method is specifically stipulated in the contract, the following must be provided: The sales contract was previously drawn up in written form..
5. Enforcement according to State Decisions
In cases where goods and services are purchased and paid for through non-cash methods into a third-party account opened at the State Treasury, the purpose is to enforce collection of money and assets held by other organizations or individuals (according to a decision of a competent state agency).
Requirement: Proof of money transfer to a third-party account at the State Treasury in accordance with the enforcement decision of a state agency; the deduction amount must correspond to the amount transferred to this account.
6. Installment purchases starting from 05 million VND.
For goods and services purchased on deferred payment or installment plans with a value of 05 million VND or more, the business establishment shall base its decision on the following: contract Purchase goods and services by written agreement. value-added tax invoice , and non-cash payment documents Goods and services purchased on deferred payment or installment plans are eligible for input value-added tax deduction. Even if non-cash payment documents are unavailable because the payment due date according to the contract or contract addendum has not yet arrived, the business is still entitled to deduct input value-added tax.
Even if the payment due date according to the contract or contract addendum has not yet arrived, temporarily deductibleIf the deadline arrives without non-cash payment documents, the business must... declaration of downward adjustment The amount of tax deducted in the tax period in which the payment obligation arises according to the contract or contract addendum.
7. For imports under 05 million VND, and for imported goods that are gifts or samples, payment is not required.
In cases where the value of imported goods and services per transaction is less than 05 million VND, or the value of goods and services purchased per transaction, including value-added tax, is less than 05 million VND (as shown on the invoice), and in cases where the business imports goods as gifts, samples, or items not requiring payment from organizations or individuals abroad, non-cash payment documents are not required for the purchased goods and services.
8. Payment authorization by the employee
In cases where goods and services are purchased to serve the production and business activities of goods and services subject to value-added tax, the transaction is authorized to... An individual is an employee of a business establishment. cashless payment financial regulations or internal regulations of the business establishment, then the business establishment Repay employees through cashless payment methods. Then the input value-added tax can be deducted.
Applies only to An individual is an employee of a business establishment.
Note:
In the case of purchasing goods or services from a taxpayer with a value of less than 05 million VND, but Multiple purchases made on the same day with a total value of 05 million VND or more. Tax deductions are only allowed in the following cases. There is a non-cash payment receipt..
Effective VAT deduction is the result of a well-designed documentation management process: standardizing payment terms from the contract stage, operating offsetting/authorization procedures according to standards, maintaining complete records of bank documents and reconciliation of accounts payable, and controlling transaction thresholds to ensure the correct application of cashless payment conditions. Businesses should maintain a transparent record lifecycle (creation – approval – storage – periodic reconciliation), digitize data for quick retrieval when needed, and conduct internal reviews before the tax declaration/settlement period. This approach minimizes compliance risks, safeguards deduction rights, and elevates financial and accounting operations towards discipline, transparency, and data-driven control.
📑 Excerpt from the law:
- Value Added Tax Law 2024 – Article 14. Deduction of input value-added tax.
- Decree 181/2025/ND-CP Article 26. Non-cash payment documents.
- Decree 52/2024/ND-CP – Regulations regarding cashless payments.