In the context of increasingly stringent tax administration, correctly identifying and implementing the timing of invoice issuance plays a crucial role in controlling a business's compliance risks. Current legislation allows for backdated invoices in certain specific cases to suit the unique characteristics of business operations, but requires strict adherence to deadlines and conditions.
This article summarizes 7 cases where backdated invoices are permitted according to regulations. Decree 123/2020/ND-CP , and Decree 70/2025/ND-CPThis helps businesses proactively manage compliance, minimize errors, and optimize financial and accounting operations.
1. Time of invoice issuance
📌 Timing of invoice issuance for the sale of goods
The time of invoicing for the sale of goods (including the sale and transfer of public assets and the sale of national reserves) is time of transfer of ownership or the right to use the goods for the buyer, regardless of whether the money has been received or not.
📌 Timing of invoicing for service provision
The time of invoicing for the provision of services is time of completion of service delivery (including providing services to foreign organizations and individuals) regardless of whether the money has been received or not.: In the case of the service provider payment in advance or during the provision of services, the time of invoicing. is the time to collect payment (This excludes cases where deposits or advances are collected to guarantee the performance of contracts for the provision of services such as: accounting, auditing, financial and tax consulting; valuation; surveying, technical design; supervision consulting; and preparation of construction investment projects.)
In cases of multiple deliveries or handover of individual items or service stages, an invoice must be issued for the quantity and value of goods or services delivered or handed over each time.
📌 Timing of invoicing for construction and installation activities
For construction and installation activities, the time of invoice issuance is the time of acceptance and handover of the project, project item, or completed construction and installation volume, regardless of whether payment has been received or not.
📌 Timing of invoice issuance for real estate business
For businesses involved in real estate development, infrastructure construction, and building houses for sale or transfer:
- In cases where ownership or usage rights have not yet been transferred: If payments are collected according to the project's progress or the payment schedule stipulated in the contract, the invoice date is the date of payment collection or as agreed upon in the contract.
- In cases where ownership or usage rights have been transferred: The time of invoice issuance shall comply with the provisions of Clause 1 of this Article.
📌 Timing of invoice issuance for passenger transport businesses using taxis
For taxi passenger transport businesses using fare calculation software as prescribed by law: at the end of the trip, the taxi passenger transport business or cooperative using fare calculation software shall issue an electronic invoice to the customer and simultaneously transfer the invoice data to the tax authority as prescribed.
📌 Timing of invoice issuance for medical examination and treatment facilities
For medical examination and treatment facilities using medical examination and treatment management and hospital fee management software, each transaction for examination, treatment, and services such as imaging, testing, and laboratory tests will have a printed receipt (for hospital fees or examination/test fees) stored in the information technology system. If the customer (the person receiving examination and treatment) does not need an invoice, at the end of the day, the medical examination and treatment facility will use the examination and treatment information and the information from the receipt to compile and create an electronic invoice for the medical services performed that day. If the customer requests an electronic invoice, the medical examination and treatment facility will create and provide an electronic invoice to the customer.
Medical examination and treatment facilities issue invoices to the social insurance agency at the time the social insurance agency settles and reimburses the medical examination and treatment costs for individuals with health insurance cards.
⚠️ Note: Invoice issuance time This is the point at which sales are completed, services are provided, and the completed work is inspected and handed over. … regardless of whether the money has been received or not.
2. Cases where invoices can be issued late.
📌 Summary:
| STT | Type | Invoice date |
|---|---|---|
| 1 | Export of goods (including processing for export) | Latest no later than the next business day from the date the goods are cleared through customs. |
| 2 | Selling goods or providing services in large quantities, with frequent transactions requiring data reconciliation. between businesses selling goods, providing services and customers, partners | At the latest the 07th of next month month in which the supply occurred. |
| 3 | Telecommunications and information technology services | Latest 02 months from the date the reconciliation service was initiated. |
| 4 | Purchase air freight services through the website. | No later than the next 05 days from the date the air transport service document is issued on the website and e-commerce system. |
| 5 | Providing air freight and insurance services through agents. | Invoicing maximum 10 days of the following month once the reconciliation is complete. |
| 6 | Casino business, electronic games with prizes. | Invoice within 01 days from the date revenue is recognized. |
📌 Export of goods (including processing for export)
For goods exports (including export processing), the time of issuing the electronic commercial invoice, electronic value-added tax invoice, or electronic sales invoice is determined by the seller, but no later than... no later than the next working day after the goods are cleared through customs. In accordance with customs regulations.
Base: Clause 1 Article 9 Decree 123/2020/ND-CP (amended and supplemented by Decree 70/2025/ND-CP).
📌 Large-scale sales and service provision with frequent transactions requiring data reconciliation.
Invoice date: Upon completion of reconciliation between businesses selling goods, providing services and customers, partners, but at the latest not too the 07th of next month month of service or not too 07 days from the end of the agreement period An agreement has been reached between the parties involved.
Applicable to the following services:
- Providing support for air transport, supplying aviation fuel to airlines, and supporting rail and water transport;
- Electricity supply (excluding the subjects specified in Point h, Clause 4);
- Television, television advertising;
- E-commerce;
- Postal and delivery services (including agency services, collection/disbursement services);
- Telecommunications (including value-added telecommunications services);
- Logistics;
- Information technology (except as provided in Point b, Clause 4) is sold on a fixed-period basis;
- Banking (excluding lending activities), international money transfers;
- Stocks, computerized lottery;
- Road usage fees are collected between the investor and the toll service provider.
- Other cases will be handled according to the instructions of the Minister of Finance.
Base: Point a, Clause 4, Article 9 Decree 123/2020/ND-CP (amended and supplemented by Decree 70/2025/ND-CP).
📌 Telecommunications and Information Technology Services
For telecommunications services (including value-added telecommunications services) and information technology services (including payment intermediary services used on telecommunications and information technology platforms), data reconciliation between service businesses must be carried out. The time of invoice issuance is the time when the data reconciliation regarding service charges according to the economic contract between the service businesses is completed. No later than two months from the month in which the connection service fee is incurred..
In cases where telecommunication services (including value-added telecommunication services) are provided through the sale of prepaid cards and connection fees are collected when customers register for services, and the customers do not request a VAT invoice or do not provide their name, address, and tax code, then at the end of each day or periodically during the month, the service business shall issue a single VAT invoice recording the total revenue generated for each service purchased without an invoice or without providing their name, address, and tax code.
Base: Point b, Clause 4, Article 9 Decree 123/2020/ND-CP (amended and supplemented by Decree 70/2025/ND-CP).
📌 Purchase air freight services through websites/e-commerce platforms.
In accordance with international practice, the time of invoicing for cases where businesses purchase air transport services through websites and e-commerce systems is no later than the latest possible date. No later than 05 days following the date the air transport service document is issued on the website and e-commerce system..
Base: Point d, Clause 4, Article 9 Decree 123/2020/ND-CP.
📌 Providing air freight and insurance services through agents.
For air transport services and insurance services provided through agents, the invoice date is the date of completion of data reconciliation between the parties, but no later than that. no later than the 10th day of the month following the month in which the event occurs..
Base: Point k, Clause 4, Article 9 Decree 123/2020/ND-CP.
📌 Casino business, electronic games with prizes
For casino and electronic gaming businesses, the latest time for issuing electronic invoices is... One day from the end of the revenue recognition date.Simultaneously, casino and electronic gaming businesses must transfer data recording the amount of money collected (from exchanging conventional currency for players at the counter, at the gaming table, and the amount collected from electronic gaming machines) minus the amount returned to players (due to winnings or unused funds) according to Form 01/TH-DT Appendix IA issued with this Decree to the tax authority at the same time as transferring electronic invoice data. The revenue determination date is the period from 00:0 to 23:59 on the same day.
Base: Point r, Clause 4, Article 9 Decree 123/2020/ND-CP (supplemented by Decree 70/2025/ND-CP).
Strict adherence to regulations regarding the timing of electronic invoicing helps businesses avoid penalties and build a transparent accounting and tax control system. Understand correctly – Do correctly This will help businesses minimize risks, improve compliance levels, and protect their interests during tax audits and inspections.