SOME NEW POINTS IN DECREE NO. 181/2025/ND-CP AND CIRCULAR NO. 69/2025/TT-BTC DETAILING THE IMPLEMENTATION OF A NUMBER OF ARTICLES OF THE LAW ON VALUE-ADDED TAX EFFECTIVE FROM JULY 1, 2025

On behalf of the Government, Deputy Prime Minister Ho Duc Phuc has just signed Decree No. 181/2025/ND-CP dated July 1, 2025, on the same day the Ministry of Finance has also issued Circular No. 69/2025/TT-BTC to detail the implementation of a number of articles of the law on value-added tax. Decree No. 181/2025/ND-CP and Circular No. 69/2025/TT-BTC take effect from July 1, 2025, including some noteworthy contents as follows:

1. Buying goods and services from 5 million VND must have non-cash payment documents

  • To be eligible for VAT deduction, there must be a non-cash payment voucher for purchased goods and services (including imported goods) of VND 5 million or more, including VAT (Article 26, Decree 181/2025/ND-CP);
  • In case goods and services purchased in service of the production and trading of goods and services subject to value-added tax are authorized to individuals who are employees of the business establishment to make non-cash payment according to the financial regulations or internal regulations of the business establishment, then the business establishment pays back to the employee in the form of non-cash payment, it is entitled to deduct input VAT (Article 26, Decree 181/2025/ND-CP).

2. Non-taxable subjects

Supplementing new guidelines on subjects not subject to VAT:

  • Adding preliminary processing methods: Grinding, crushing, polishing seeds, pooling seeds, separating into parts, removing bones, chopping, peeling, crushing, laminating, canning airtight (Clause 1, Article 4, Decree 181/2025/ND-CP);
  • Promulgating the list of export products being exploited natural resources and minerals that have not yet been processed into other products and exported products being exploited natural resources and minerals that have been processed into other products that are not subject to tax (Appendices I and II of Decree 181/2025/ND-CP);
  • Supplementing guidance on dossiers and procedures that need to be presented when requested by state management agencies to prove that they are not subject to value-added tax (Article 3, Circular 69/2025/TT-BTC).

3. Deduction of value-added tax on goods and services changed from non-taxable to taxable

For goods and services transferred from non-VAT-liable to VAT-liable under the provisions of the VAT Law, business establishments are only allowed to declare and deduct input VAT on goods and services used for the production and trading of VAT-liable goods and services arising from July 1, 2025 (Clause 12, Article 23, Decree 181/2025/ND-CP).

4. Tax refund

  • Guidance on tax refund for business establishments that only produce goods or provide services are subject to the VAT rate of 5%, if there is an input VAT amount that has not been fully deducted from VND 300 million or more after 12 consecutive months or 04 consecutive quarters, they shall be entitled to VAT refund. In case of multiple value-added tax rates, the input value-added tax amount used for the production of goods or provision of services subject to 5% tax must be separately accounted for, if it cannot be separately accounted for the input value-added tax amount used for the production of goods, provision of services subject to the VAT rate of 5% is determined according to the ratio between the turnover of goods production activities and the provision of services subject to the VAT rate of 5% to the total turnover of taxable goods and services in the tax refund period (Article 31, Decree 181/2025/ND-CP);
  • Guidance on how to determine the refundable value-added tax amount on exported goods and services in case the business establishment in the month or quarter has both exported goods and services and goods and services for domestic consumption, determination of the refundable value-added tax amount for goods production activities, providing services subject to the VAT rate of 5% (Appendices II, III, Circular 69/2025/TT-BTC).