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Official letter No. 2054/TCHQ-GSQL about using e-invoices for exporting goods

Exporting plays a intergral role in expanding domestic enterprises’ consumption markets, production scale, thereby promoting economic growth; and it is also a way to bring large foreign currency to the country. The number of businesses involved in exporting and exported goods are increasing; however, there are quite a lot of businesses that encounter difficulties in processing customs procedures for exporting goods such as using electronic invoices in the customs dossier or the time of issuing electronic invoices (hereinafter referred as “e-invoice”) for exported goods

In order to promptly support businesses, on June 3, 2022, the General Department of Customs issued Official Letter No. 2054/TCHQ-GSQL on the use of electronic invoices for exported goods (hereinafter referred as “Official letter 2054”).

Accordingly, the responses to Official Letter 2054 are summarized in the following table:


Detailed information

Legal basis

1. Regulations on

invoices in

export customs


- The customs dossier of exports shall include commercial invoices or equivalent documents value in case the buyer has to pay the seller.

- There is no requirement to issue additional VAT electronic invoices in export procedures

- The International practice;

- Article 24 of the Law on


- Point b, Clause 1, Article 16 of Circular 38/2015/TT-BTC and amendment to Clause 5,

Article 1 of Circular 39/2018/TT-BTC;

2. Time to issue

e-invoices for

exported goods

Basis for issuing VAT invoices for exported goods:

- In the case of export entrustment: there is a confirmation from the customs authority after the goods have been actually exported

- For the exporters who declares and pays

value-added tax by the credit method including export processors: after completing the procedures for exported goods

According to the above regulations, the VAT invoices for exports shall be issued after completing export customs procedures by exporters.

Therefore, at the time of customs clearance for exported goods, the customs declarant is unable to issue a VAT invoice for submitting with the customs dossier

- Points b, c, Clause 3, Article 13 of Decree

123/2020/ND-CP dated

October 19, 2020.

Official letter 2054 also notices that:

• The issuance of an e-invoice complies with Vietnamese law, the time to issue this invoice is after the customs clearance.

• Commercial invoices in international trade comply with the international practices, the time to issue such invoice is prior ti the customs clearance.

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