SOME NEW POINTS IN CIRCULAR NO. 32/2025/TT-BTC REPLACING CIRCULAR NO. 78/2021/TT-BTC GUIDING THE LAW ON TAX ADMINISTRATION ON INVOICES AND DOCUMENTS

On 31/05/2025, the Ministry of Finance issued Circular No. 32/2025/TT-BTC replacing Circular No. 78/2021/TT-BTC dated 17/09/2021 guiding the implementation of a number of articles of the Law on Tax Administration dated 13/06/2019, Decree No. 123/2020/ND-CP dated 19/10/2020 of the Government regulating invoices and documents. Circular No. 32/2025/TT-BTC takes effect from June 1, 2025 and has a number of noteworthy contents as follows:

1. Electronic personal income tax deduction documents

From June 1, 2025, personal income tax deduction organizations must stop using electronic personal income tax withholding vouchers that have been implemented in accordance with previous regulations and switch to applying electronic personal income tax withholding vouchers according to the provisions of Decree No. 70/2025/ND-CP dated March 20, 2025 of the Government.

2. Authorization for e-invoicing

Do not require the third party to receive the authorization to be a party with an associated relationship with the seller (the third party only needs to be eligible to use e-invoices and not in the case of stopping the use of e-invoices). In case the seller of goods being a business household or business individual authorizes the e-commerce platform management organization to issue e-invoices for the sale of goods or services, the e-commerce platform management organization shall notify the tax authority.

3. Addition of invoice number sample symbols, invoice type symbols

Supplementing new symbols and models of invoice numbers includes:

• No. 7: Reflecting e-commerce invoices;
• No. 8: Reflecting value-added invoices integrated with receipts for collection of taxes, charges and fees;
• No. 9: Reflecting sales invoices integrated with receipts for collection of taxes, charges and fees;
• X: Applies to e-commerce invoices.

4. New guidance on the application of e-invoices to some other cases

Article 6, Circular 32/2025/TT-BTC has added new guidance on the application of e-invoices to a number of other cases as follows:

• In other cases, regulations on the time of invoicing for the sale of goods or provision of services in large quantities arising frequently, it is necessary to have time to compare data between enterprises selling goods or providing services and customers and partners who are invoiced according to the provisions of Point a, Clause 4, Article 9 of Decree No. 123/2020/ND-CP (amended amended and supplemented by Clause 6, Article 1 of Decree No. 70/2025/ND-CP), including: derivative products in accordance with the law on credit institutions, the law on securities and the law on commerce, the law

on value-added tax, industrial catering services, etc services of the Goods Exchange, credit information services, passenger transportation services by taxi (for customers being businesses and organizations);

• Supplementing guidance on invoicing for financial leasing activities and handling invoicing when the financial leasing contract is terminated ahead of schedule.

5. Value Added invoice tax refund declaration

Supplementing the guidance on value-added invoices tax refund returns, the contents of value-added invoices tax refund declarations include 03 parts:

• Part A is for businesses selling goods with tax refund made when selling goods;
• Part B is for customs offices to make to record the results of inspection of value-added invoices declarations of tax and goods refunds, and calculate the refundable value-added tax amounts for foreigners;
• Part C is for commercial banks that are tax refund agents.

6. Business activities applying invoices from cash registers

Clause 3, Article 8 of Circular 32 provides guidance on cases where enterprises have many business activities, enterprises registering to use e-invoices generated from cash registers apply to the following activities: Selling goods, providing services directly to consumers (commercial centers; supermarkets; retail (except for automobiles, motorcycles, motorcycles and other motorized vehicles); Eating; restaurant; hotel; Passenger transportation services, direct support services for road transport, arts, entertainment, film screening activities, and other personal service services in accordance with regulations on Vietnam’s economic system).

Enterprises registering to use e-invoices with codes or e-invoices without codes of tax authorities apply to other business activities.