SOME NEW HIGHLIGHTS IN CIRCULAR 32/2025/TT-BTC: DETAILS AND UPDATES
Jul 09, 2026
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On May 31, 2025, the Ministry of Finance issued Circular 32/2025/TT-BTC, Guiding the implementation of a number of articles of the 2019 Tax Administration Law, Decree 132/2020/ND-CP dated October 19, 2020 of the Government on invoices and documents, Decree 70/2025/ND-CP dated March 20, 2025. Accordingly, the following are some new points of Circular 32/2025/TT-BTC replacing Circular 78/2021/TT-BTC, detailed as follows:
Content
Regulations at
Current Regulations
Updated in Circular 32/2025/ND-CP
Do not require the authorized seller to issue an invoice to be an affiliated party.
From June 1, 2025, according to Point a, Clause 1, Article 4 of Circular 32/2025/TT-BTC:Remove the requirement that the seller must be an enterprise, economic organization or other organizationThe third party issuing the invoice is not required to have an affiliated relationship with the seller.
Add invoice denominator and type symbols
Article 5 of Circular 32/2025/TT-BTC
Add new symbols to classify invoices:Number 7: E-commerce invoice.Number 8: Value-added invoice integrated with tax, fee, and charge receipts.Number 9: Sales invoice integrated with tax, fee, and charge receipts.Letter X: Applicable to e-commerce invoices.
Apply electronic invoices from cash register
Use electronic invoices generated from cash registers
Expanding the permission for business households and individual businesses to authorize a third party to create electronic invoices, without requiring the third party to have an affiliated relationship with the seller.
Applicable to some other cases
Article 6 of Circular 32/2025/TT-BTC
Add some cases where electronic invoices are applied, including:Derivative productsIndustrial catering servicesServices at the Commodity ExchangeFinancial leasing activities (including instructions for making contracts when leasing and when terminating contracts early)Cases of selling and providing large quantities of services, arising frequently, requiring time to reconcile data.
Supplementing regulations on VAT invoice content and tax refund declaration
Consists of 3 parts
Article 7 of Circular 32/2025/TT-BTC
VAT invoice cum tax refund declaration consists of 3 parts:Part A: The selling enterprise makes when selling goods.Part B: The customs authority records the results of goods inspection and determines the amount of VAT that foreigners are refunded.Part C: The commercial bank (tax refund agent) makes.
Content
Regulations at
Current Regulations
Updated in Circular 32/2025/ND-CP
Businesses utilize e-invoices generated from cash registers
Clause 3, Article 8, Circular 32/2025/TT-BTC
Enterprises with many business activities must register to use electronic invoices generated from cash registers applicable to the following activities:Selling goods and providing services directly to consumers (shopping malls; supermarkets; retail (except for cars, motorbikes, motorcycles and other motor vehicles);Food and beverage; restaurants; hotels;Passenger transport services, direct support services for road transport, art services, entertainment, recreation, cinema activities, other personal services according to regulations on the Vietnamese Economic Sector System.
Cases where it is mandatory to use electronic invoices from cash registers
Clause 5, Article 12, Circular 32/2025/TT-BTC
In case the enterprise has registered to use electronic invoices with codes or electronic invoices without codes from the tax authority to serve the activities of selling goods and providing services directly to consumers before June 1, 2025, it can choose:Either switch to using electronic invoices generated from cash registers according to the provisions of Decree 70/2025/ND-CP.Or continue to use electronic invoices registered with the tax authority.
Handling incorrect invoices
If the invoice is found to have been created in accordance with the provisions of Decree 51/2010/ND-CP, Decree 04/2014/ND-CP and guiding documents of the Ministry of Finance
Clause 8, Article 12, Circular 32/2025/TT-BTC
The seller and the buyer must make a written agreement stating the incorrect content and issue a new electronic invoice (an electronic invoice with a tax authority code or an electronic invoice without a code) to replace the incorrectly issued invoice.The electronic invoice replacing the incorrectly issued invoice must have the words “Replacement for invoice Form No…. symbol… number… date… month… year”.The seller signs the new electronic invoice replacing the incorrectly issued invoice to send to the buyer (in case of using an electronic invoice without a code) or the seller sends it to the tax authority to be granted a code for the electronic invoice replacing the issued invoice (in case of using an electronic invoice with a tax authority code).
The time of signing the invoice is different from the time of creating the invoice.
Time of creation and signing: No restriction
Time of creation and signing: Time of digital signing, sending to tax authority for code issuance or time of data transfer to tax authority is no later than the next working day from the time of invoice creation.
Content
Regulations at
Current Regulations
Updated in Circular 32/2025/ND-CP
Adding criteria to identify high tax risks in electronic invoice registration
Article 9 Circular 32/2025/TT-BTC
There are 05criteriato determine high tax risks in registering to use electronic invoices, including: Criterion 1: Taxpayers whose owners or legal representatives, business household representatives, business individuals or private enterprise owners are also owners or legal representatives, business household representatives, business individuals or private enterprise owners have conclusions from competent state management agencies that have committed acts of fraud or buying and selling invoices on the tax authority’s database.Criterion 2: The taxpayer has an owner or legal representative, representative of a business household, individual business or private enterprise owner on the list of suspicious transactions, according to the provisions of the Law on Anti-Money Laundering 2022.Criterion 3: The taxpayer registers the head office address without a specific address according to administrative boundaries or located in an apartment building (excluding apartments permitted for business purposes according to the provisions of law); or the business location is outside the scope of the province/city where the enterprise has its head office/branch.Criterion 4: The taxpayer has a legal representative or owner who is also the legal representative or owner of the taxpayer in the status of “Taxpayer has stopped operating but has not completed the tax code termination procedure” or in the status of “Taxpayer is not operating at the registered address”, the taxpayer has committed violations of tax, invoices, and documents according to the instructions of the Minister of Finance. Criterion 5: The taxpayer has other signs of risk as determined by the tax authority and has notified the taxpayer to know and explain
Content
Regulations at
Current Regulations
Updated in Circular 32/2025/ND-CP
From June 1, 2025, must switch to electronic personal income tax deduction documents
Clause 2, Article 12, Circular 32/2025/TT-BTC
From the time Decree No. 70/2025/ND-CP dated March 20, 2025 of the Government takes effect from June 1, 2025, organizations deducting personal income tax must stop using electronic personal income tax deduction documents that have been made in accordance with previous regulations and switch to applying electronic personal income tax deduction documents according to the provisions of Decree No. 70/2025/ND-CP dated March 20, 2025 of the Government. For personal income tax deduction documents that have been made in accordance with previous regulations, if it is discovered that the personal income tax deduction document has been made incorrectly after applying Decree No. 70/2025/ND-CP, a new electronic personal income tax deduction document must be made to replace the incorrectly made personal income tax deduction document.
Note:
All information contained in this document is of a general nature and is not intended to provide advice. Whilst we endeavour to provide the most accurate and up-to-date information possible, we cannot guarantee that the information is accurate when it is received or will remain accurate in the future. No person should act on the information contained in this document without obtaining appropriate professional advice after considering the circumstances of the particular situation.
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