CIRCULAR NO. 32/2025/TT-BTC: DETAILS AND UPDATES
- RSM Việt Nam
- Jun 2
- 5 min read
Updated: Jun 4
On May 31, 2025, the Ministry of Finance issued Circular 32/2025/TT-BTC, providing guidance on the implementation of several provisions of the 2019 Law on Tax Administration, Government Decree 123/2020/NĐ-CP dated October 19, 2020 on invoices and documents, and Decree 70/2025/NĐ-CP dated March 20, 2025. Accordingly, the following are some of the new points in Circular 32/2025/TT-BTC, which replaces Circular 78/2021/TT-BTC:
1. No Requirement for the Seller to Authorize an Affiliated Party to Issue Invoices
According to Point a, Clause 1, Article 4 of Circular 32/2025/TT-BTC, effective from June 1, 2025, the Ministry of Finance no longer requires that the seller of goods or service provider must be an "enterprise, economic organization, or other organization." Furthermore, it is no longer required that the third party authorized to issue invoices must have an affiliated relationship with the seller.
2. Addition of Electronic Commercial Invoice Codes
According to Clause 1, Article 5 of Circular 32/2025/TT-BTC, the invoice form codes have been updated to include Form No. 7, which represents electronic commercial invoices.Additionally, the invoice type symbol "X" has been added to denote electronic commercial invoices.For example: The invoice symbol 7K25XAB refers to an electronic commercial invoice without a tax authority code, issued in 2025, and registered by an enterprise with the tax authority.
3. Additional Cases Where E-Invoices Are Required
According to Article 6 of Circular 32/2025/TT-BTC, several new situations have been added where electronic invoices (e-invoices) must be used, as follows:
- Sales of goods or services with large volumes and frequent transactions that require time for data reconciliation before invoice issuance. These include:Derivative products, Industrial catering services, Services provided by the Commodity Exchange.
- Financial leasing activities subject to value-added tax (VAT) must issue VAT invoices for leased assets. This applies to: Assets purchased domestically (with a VAT invoice), or Imported assets (with proof of VAT payment at the import stage).
When issuing invoices, the total VAT amount on the output VAT invoice must match the VAT amount shown on the input VAT invoice for the leased asset (or the import VAT payment document). The applicable VAT rate is denoted by the symbol “CTTC” (financial leasing).
4. Additional Provisions on the Content of VAT Invoices Used as Tax Refund Declarations
According to Article 7 of Circular 32/2025/TT-BTC, the VAT invoice that also serves as a tax refund declaration includes three parts:
Part A – Completed by the VAT refund-eligible seller upon sale of goods, includes:
Invoice title: “INVOICE CUM TAX REFUND DECLARATION”
Invoice code and form number
Seller's information: company name, address, and tax identification number
Customer’s information: full name, nationality, passport or immigration document details (number, issue date, expiry date)
Product information: name, unit, quantity, unit price; amount excluding VAT; VAT rate; total VAT by rate category; total VAT amount; and total amount including VAT
For goods, must specify: brand name, product code (serial number, model if any), country of origin for imported goods, machine number for electronic/mechanical items
Seller’s digital signature and buyer’s signature on the e-invoice display
Payment method: clearly state the amount paid by each method—cash or international card (with card name and number)
Part B – Completed by the customs authority to record inspection results and calculate VAT refund amount. Includes:
Serial number of goods
Product name
Quantity
VAT amount listed on the invoice and the refundable amount
Time of inspection (date/month/year)
Name and signature of the customs officer
Part C – Completed by the commercial bank acting as the tax refund agent, includes:
Flight/train number and date of the foreign passenger’s departure
VAT amount refunded to the foreigner
Payment method: clearly state amount refunded in cash or via international card (with card name and number)
Payment time: specify date/month/year
5. Additional Criteria for Determining High Tax Risk in E-Invoice Registration
According to Article 9 of Circular 32/2025/TT-BTC, five criteria are set to identify high tax risk in the registration for electronic invoice usage:
Criterion 1: The taxpayer's owner or legal representative (including household or individual business representatives or private business owners) is also the owner or legal representative of another entity determined by a competent state agency to have committed invoice fraud or engaged in the buying/selling of invoices, as recorded in the tax authority’s database.
Criterion 2: The taxpayer's owner or legal representative (including household or individual business representatives or private business owners) appears on the list of suspicious transactions under the Law on Anti-Money Laundering 2022.
Criterion 3: The taxpayer registers a head office address that is non-specific (not clearly defined according to administrative boundaries) or located in an apartment building (excluding those legally permitted for business use), or operates at a business location outside the city/province where the head office or branch is located.
Criterion 4: The taxpayer’s legal representative or owner is also the legal representative or owner of another taxpayer that is currently: In the status of “ceased operations but not yet completed tax code termination procedures” or In the status of “not operating at the registered address.”
In addition, the taxpayer has violated tax, invoice, or documentation regulations as per the Ministry of Finance’s guidelines.
Criterion 5: The taxpayer exhibits other signs of tax risk as determined by the tax authority, and has been notified and requested to provide an explanation.
6. From June 1, 2025: Mandatory Use of New Electronic PIT Withholding Vouchers
According to Clause 2, Article 12 of Circular 32/2025/TT-BTC:
Effective date: This Circular takes effect on June 1, 2025, replacing Circular No. 78/2021/TT-BTC dated September 17, 2021 (which provided guidance on implementing certain provisions of the 2019 Law on Tax Administration and Decree No. 123/2020/NĐ-CP dated October 19, 2020 on invoices and documents).
From the effective date of Decree No. 70/2025/NĐ-CP (March 20, 2025):
Entities withholding personal income tax (PIT) must stop using previously applied electronic PIT withholding vouchers.
They must switch to using new electronic PIT withholding vouchers in accordance with Decree 70/2025/NĐ-CP.
If errors are found in vouchers issued under previous regulations, they must be replaced with new electronic vouchers issued under the new regulation.
Therefore, from June 1, 2025, PIT withholding entities must cease using old electronic withholding vouchers and switch to the new format per Decree 70/2025/NĐ-CP.
7. Repeal of Certain Provisions in Decree 123 Starting June 1, 2025
According to Clause 4, Article 2 of Decree 70/2025/NĐ-CP, the following provisions of Decree 123/2020/NĐ-CP are repealed as of June 1, 2025:
Clause 10, Article 3
Point g, Clause 4, Article 9
Clause 2, Article 33
Article 37
Clause 2, Article 50
Article 51
Clauses 3 and 4, Article 52
Clause 5, Article 53
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