Circular 78 covering the implementation of the latest Law on Tax Administration regarding e-invoices and related documents.

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Circular 78 covering the implementation of the latest Law on Tax Administration regarding e-invoices and related documents

Circular 78 takes effect on 1 July 2022 and further encourages taxpayers in Vietnam to implement electronic invoices before the effective date, offering a comprehensive guide and timeline for the implementation. In this article, we delve into the guidance released by the authorities and explain how it affects the Vietnamese taxpayers from a practical perspective.

The Circular stipulates a number of provisions and clarifications on e-invoices, including authorization to issue e-invoices, sample display of various types of e-invoices, form number & serial number, instruction for handling mistaken on issue e-invoice as well as e-invoices application to other cases.

Authorization to issue e-invoices

Sellers have the right to authorize a third party (a related party of the seller) to issue e-invoices for the sale of goods and services. The authorized party is eligible to issue e-invoices as regulated, and the authorization must be agreed in writing (i.e. contract or an agreement). Both the authorizer and the authorized party are required to notify the tax authorities about the authorization in a prescribed form.

Verification codes for e-invoices

Where enterprises are using e-invoices without verification codes and would like to change to e-invoices with verification codes, they can change the information as instruction under the provision of Article 15, Decree 123/2020.

Users of e-invoices without a verification code are required to transmit the e-invoice data to the tax authority no later than the date when the e-invoice is sent to the buyer. There are exceptions only for certain cases such as enterprises active in telecommunication, insurance, banking, air transportation, securities.

E-invoices with a verification code issued from an Electronic Cash Register (ECR) which has an internet connection to transmit data to the tax authorities (relevant for supermarkets, food and beverage establishments, restaurants, retail businesses, etc.) are required to ensure the following principles:

  • They are required to recognize the printed invoices from the ECR which is connected to transmit data to the tax authorities
  • No digital signature is required
  • Expenses for purchase of goods and services which use invoices created from the ECR are considered to have sufficient legal invoices and documents when determining tax obligations

Errors and adjustment provisions for e-invoices

The circular also provides guidance on how to handle issued e-invoices with errors. For e-invoices with errors that are required to be adjusted, cancelled or replaced, the seller can use a prescribed form to amend each or multiple e-invoices. The amendment form can be submitted to the tax authority at any time but no later than the final day of the VAT declaration period of the adjustment invoice.

Conditions for using e-invoices solutions

The Circular also prescribes the specific conditions which apply for companies providing e-invoice solutions. Accordingly, enterprises should engage and prepare written agreements with e-invoice solution companies which meet certain conditions (subject, financial, human resources and technical) and are listed in the publicly announced website of the General Department of Taxation.

The General Department of Taxation also selects and engages in contractual agreements with organization providing the service of transmitting and archiving data to the tax authority, which meet certain criteria as prescribed.

Planning and phasing

The Ministry of Finance directed the General Department of Taxation to plan the e-invoice implementation in accordance with Decree 123/2020 and Circular 78/2021 in two phases. Phase 2 covers 6 provinces and cities: Hanoi, Ho Chi Minh City, Hai Phong, Quang Ninh, Phu Tho and Binh Dinh following Decision no.1417 dated 27 September 2021 by the General Department of Taxation.


If you need any assistance with these or any other matters relevant for international investors in Vietnam, our experts are ready to work with your company to ensure you understand how the above will apply to your specific situation in Vietnam.


Contact our teams for expert support and further information on managing corporate compliance in Vietnam.

Phung Nguyen – Accounting Director –

Matthew Lourey – Managing Partner –

Last updated on October 13, 2021
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