Official Letter 1109/CT-TTHT on Issuing Invoices for Sale of Goods and Provision of Services

In response to the contents outlined in Official Letter No. 1802/CVT-TH dated February 18, 2025, from Thao Ha Trading Co., Ltd. (the company), regarding the issuance of invoices for the sale of goods and services to individual customers on the same VAT invoice, the Thanh Hoa Tax Department provides the following comments:

According to Article 4, Article 9, and Article 10 of Decree No. 123/2020/ND-CP dated October 19, 2020, of the Government on invoices and documents:

Article 4. Principles for the issuance, management, and use of invoices and documents

1. When selling goods or providing services, the seller must issue an invoice to the buyer (including cases of goods or services used for promotion, advertising, samples; goods or services given, donated, exchanged, paid in lieu of wages to employees, and for internal consumption (except for goods transferred internally for the continuation of the production process); goods being lent, borrowed, or returned), and must fully state the contents according to Article 10 of this Decree. In case of using electronic invoices, the format must follow the data standard set by the tax authority under the provisions of Article 12 of this Decree.

Article 9. Time of invoice issuance

1. The time of invoice issuance for the sale of goods (including the sale of state-owned assets, seized property, state treasury property, and national reserve goods) is the time when ownership or the right to use the goods is transferred to the buyer, regardless of whether payment has been received.

Article 10. Contents of the invoice

1. The name of the invoice, the invoice symbol, and the invoice template code, as specified below:

a) The name of the invoice is the name of each type of invoice defined in Article 8 of this Decree, displayed on each invoice, such as: VALUE-ADDED INVOICE, VALUE-ADDED INVOICE FOR TAX REFUND DECLARATION, VALUE-ADDED INVOICE WITH SALES INVOICE, SALE OF PUBLIC ASSETS INVOICE, STAMPS, TICKETS, CARDS, NATIONAL RESERVE SALE INVOICE.

b) The invoice template code, invoice symbol, shall follow the guidance of the Ministry of Finance.

Based on the above regulations, when selling goods or providing services, the seller must issue an invoice to the buyer in accordance with Articles 4, 9, and 10 of Decree No. 123/2020/ND-CP. Accordingly, the company must issue invoices in cases where customers do not take invoices. The practice of consolidating all the goods sold in a day to issue a single VAT invoice at the end of the day is not in line with current regulations.

The Thanh Hoa Tax Department advises Thao Ha Trading Co., Ltd. to base its operations and actual records on the legal provisions to ensure compliance with the law.