Vietnam Updates E-Invoice Regime: Highlights from Circular 32

In recent months, Vietnam has accelerated its efforts to upgrade its tax management regime, as evidenced by newly released directives. Among the most notable updates recently is Circular No. 32/2025/TT-BTC (“Circular 32”), which provides specific regulations for electronic invoice (e-invoice) issuance authorization, numbering, and other related matters. This article highlights the key points of this circular, along with the most notable changes for June 2025.

The scale and speed of Vietnam’s latest effort to revamp its tax management system are expected to create significant pressure on businesses’ tax management. This situation necessitates close monitoring for new regulations and the need for comprehensive updates to ensure timely compliance adaptations among firms.

On May 31, 2025, Vietnam’s Ministry of Finance issued Circular 32, which prescribes a wide range of invoice management rules under previous decrees. While examining the most significant highlights under Circular 32, this article also discusses the key regulatory changes effective from June 2025.

Overall scope of Circular 32

The circular primarily provides guidelines for certain contents of invoices and records in accordance with the 2019 Law on Tax Administration, Decree No. 123/2020/ND-CP (“Decree 123”) and Decree No. 70/2025/ND-CP (“Decree 70”). It also establishes a management regime for other related aspects, including:

• Organizing measures to encourage consumers to obtain invoices when purchasing goods or using services;
• Authorization for issuing e-invoice;
• Invoice numbering regime;
• Special cases of e-invoice usage;
• Content of VAT invoice cum refund claim;
• E-invoice conversion;
• Criteria for identifying taxpayers posing high tax risks upon applying for the use of e-invoices;
• Use of records; and
• Eligibility criteria for providers of e-invoice solutions and relevant services.

Regulations on e-invoice issuance authorization

Seller and authorized e-invoice issuers no longer need to be related parties

In comparison to Circular No. 78/2021/TT-BTC, Circular 32 has expanded the pool of eligible providers for e-invoice issuance authorization services by removing the requirement that the seller and its authorized e-invoice issuers must be related parties.

Accordingly, the new circular only requires providers to be eligible to use e-invoices and not to be subject to suspension cases as outlined in Article 16 of Decree No. 123/2020/ND-CP (amended by Clause 12, Article 1 of Decree No. 70/2025/ND-CP). This expanded scope allows sellers greater flexibility in choosing e-invoicing partners without being constrained by affiliate relationships.

Mandatory information on contracts/agreements for e-invoice issuance authorization

Clause 2, Article 4, Circular 32, requires an e-invoice authorization contract or agreement to include the following information:

• Name, address, tax code or personal identification number, and digital certificate of both the authorizing party (seller) and the authorized party (e-invoice provider);
• Information on the authorized e-invoice, including type, symbol, and model number);
• Purpose, term, payment method, and responsibility for payment of goods and services; and
• Responsibility for storing and presenting documents when requested by competent authorities.

Additionally, the circular requires that e-invoices issued by authorized parties must be consistent with the tax calculation method of the authorizing party.

E-commerce platform responsibilities when authorized by sellers

Circular 32 specifies that when business households and individual enterprises authorize an e-commerce platform to issue e-invoices on their behalf for goods and services sold, the e-commerce platform must inform the tax authority for the business household or individual.

This regulation is essential amid the evolving landscape of e-commerce, designed to assist small business households and individuals who use major platforms, like Shopee and Lazada, while also enhancing the accountability of e-commerce platforms in adhering to tax obligations.

Updated e-invoice numbering regime

Circular 32/2025/TT-BTC outlines the regime for the numbering format of e-invoices, consisting of two main parts:

• Form number: A digit from 1 to 9 based on the type of e-invoice; and
• Reference code: A code of 6 characters, including letters and numbers, indicating whether the invoice contains the tax authority’s authentication code, along with the year of issuance and the type of e-invoice.

Special cases for applying e-invoice

For financial leasing activities

Circular 32 provides detailed regulations on issuing e-invoices for financial leasing activities, highlighting the following key points:

• Mandatory issuance of VAT invoices: Financial leasing organizations must issue VAT invoices for leased assets subject to VAT, which require specific input invoices/documents (either domestic purchases or imports):
  • Domestic purchases must include a valid input VAT invoice; and
  • Imported assets must have documentation proving VAT payment at the import stage.
• Matching input and output VAT amounts: The total VAT on the output invoice (issued upon leasing the asset) must align with the VAT on the input invoice (for domestic assets) or import VAT payment documentation (for imported assets).
• Use of the code “CTTC” on VAT invoices to indicate the VAT rate for financial leasing activities, rather than stating a specific rate (0, 5, or 10 percent).
• For assets not subject to VAT or lacking input invoices/documents, VAT should not be mentioned on the invoice.
• Sale of repossessed assets: When the financial leasing organization sells repossessed assets (due to non-payment by the customer), a VAT invoice must be issued and provided to the customer. The invoice must clearly state: the VAT amount reimbursed for the repossessed asset, the “CTTC” code for tax rate, and the VAT calculated on the remaining value (excluding VAT) as per the repossession record.

For high-volume, frequent transactions

Circular 32 governs the distribution of e-invoices for situations involving high-volume or recurring transactions of goods and services that necessitate reconciliation between the seller (enterprise) and the buyer or partner. This regulation permits enterprises to issue e-invoices after completing data reconciliation in specific exceptional circumstances, rather than at the moment of goods or services delivery. Relevant cases include:

• Derivative products: Governed by regulations concerning credit institutions, securities, commerce, and VAT;
• Industrial catering services: Such as supplying meals to factories, schools, or hospitals;
• Commodities exchange services: Trading goods on exchanges (like agricultural products and metals); and
• Credit information services: Offering credit reports and financial insights.
• Taxi passenger transport services: Applicable when customers are businesses or organizations.

Eligible subjects for e-invoices from cash registers

Clause 5 of Article 12 in Circular 32 specifies the situations where entities can register to use e-invoices generated from cash registers. These entities must directly sell goods or services to consumers and have registered with the tax authority to utilize e-invoices. However, they must ensure that the e-invoices include the following information:

• The tax authority’s code or electronic data, which encompasses the seller’s name, address, and tax code, along with the buyer’s name, address, tax code, personal identification number, or phone number, if requested;

• Details of the goods or services, including their name, unit price, quantity, and payment price, highlighting the selling price before VAT, applicable VAT rate, VAT amount, and the total amount payable including VAT for organizations and enterprises taxed under the deduction method; and
• The invoice creation date, formatted according to the tax authority’s standard data requirements as outlined in Article 12 of Decree 123, amended and supplemented by Clause 9, Article 1 of Decree 70.

Key changes starting June 1, 2025

Mandatory e-invoices for certain businesses

As mandated by Decree 70, individuals and household businesses with annual revenues of VND 1 billion (approximately US$38,399) or more in specific sectors are required to use e-invoices generated from cash registers.

Guidelines for personal income tax withholding certificates

Starting June 1, 2025, entities that withhold personal income tax (PIT) must stop using electronic PIT withholding certificates issued under prior regulations and begin using certificates that comply with Decree 70. If any errors are found in PIT withholding certificates issued earlier, once Decree 70 is applied, a new electronic certificate must be issued to replace the erroneous one.

Conclusion

Circular 32 represents a significant advancement in Vietnam’s tax management and e-invoicing system, showcasing the government’s commitment to modernizing tax administration. With changes such as the removal of related party requirements for e-invoice issuance authorization and clarified responsibilities for e-commerce platforms, businesses can expect greater flexibility and accountability.

As Vietnam moves towards eliminating its flat tax system by 2026, companies must remain vigilant and adapt to these evolving regulations to ensure compliance and optimize their operations in this new framework.

(US$1 = VND 26,012.5)