📢 CIRCULAR 32/2025/TT-BTC: 6 NEW POINTS ON INVOICES - DOCUMENTS THAT EVERY BUSINESS MUST KNOW FROM JUNE 1, 2025!

Reference only, original in Vietnamese here

On May 31, 2025, the Ministry of Finance issued Circular 32/2025/TT-BTC, replacing the entire Circular 78/2021/TT-BTC - a major legal milestone on electronic invoices. From June 1, 2025, millions of businesses and business households must comply with the new regulations, if they do not want to fall into the "high tax risk zone".
📌 Below are 6 notable new points - and important warnings for accountants - finance - business administrators:

1️⃣ Loosening the conditions for authorizing invoice creation - No longer requiring related parties
📑 Basis: Point a, Clause 1, Article 4, Circular 32/2025/TT-BTC
According to the new regulations, the seller is no longer limited to being an affiliated organization when authorizing a third party to create invoices on its behalf. This reduces barriers for chain business models, distribution, logistics...

👉 Note: The authorization of invoice issuance still requires an authorization contract and notification to the tax authority.

2️⃣ The appearance of "E-commerce invoice" - New symbol "X"

📑 Basis: Clause 1, Article 5 of Circular 32/2025/TT-BTC
For the first time, the Ministry of Finance officially recognizes E-commerce invoices, with form number 7 and invoice type symbol "X".
🧾 For example: Invoice 7K25XAB is an e-commerce invoice without a code, issued in 2025, registered with the tax authority.

👉 Enterprises selling through e-commerce platforms, SaaS, exporting software... need to adjust the invoice system promptly.

3️⃣ Expanding the subjects required to use electronic invoices
📑 Basis: Article 6 of Circular 32/2025/TT-BTC
The following activities are required to apply electronic invoices:
Regular, large-scale transactions (industrial catering, derivative products, commodity trading floors);
VAT-based financial leasing: Output invoices must match input VAT, showing the code "CTTC" → Be careful when accounting!
👉 Note: Many business models that have never issued invoices will now be required to comply. Otherwise, the risk of being administratively sanctioned and taxed is very high.

4️⃣ The appearance of “Invoice cum VAT refund declaration for foreigners”
📑 Basis: Article 7 of Circular 32/2025/TT-BTC
A new type of invoice has appeared: Invoice cum VAT refund declaration, consisting of 03 parts:
Part A: Enterprises make when selling goods;
Part B: Customs authority confirms goods leaving the country and VAT is refunded;
Part C: Bank - tax refund agent confirms payment method for foreign customers.
👉 Enterprises selling goods to foreigners at airports, shopping malls... need to update this new invoice form to make tax refunds in accordance with regulations.

5️⃣ 5 more criteria to identify enterprises with high tax risks - Need to be especially vigilant!
📑 Basis: Article 9 Circular 32/2025/TT-BTC
If a business falls into one of the following 5 groups, it may be subject to special control regarding invoices:
Has a representative involved in the act of buying and selling invoices, and has been handled;
Has suspicious transactions according to the 2022 Anti-Money Laundering Law;
Headquarters are unclear, located in an apartment building that is not allowed to do business;
Related to a business that has stopped operating, absconded, or violated taxes;
There are other signs of risk determined by the tax authority.
👉 If falling into this category, the business may be denied electronic invoice registration, subject to surprise inspections, or have its invoice code stopped.

6️⃣ Mandatory conversion to new electronic personal income tax deduction vouchers from June 1, 2025
📑 Basis: Clause 2, Article 12, Circular 32/2025/TT-BTC & Decree 70/2025/ND-CP
Organizations and enterprises that deduct personal income tax must stop using the old deduction voucher form and switch to the new form according to Decree 70/2025/ND-CP.
👉 If errors are found in the old voucher after June 1, 2025, do not correct the old form, but create a new one according to the new standardized electronic form.

🚨 WARNING FOR ACCOUNTANTS - TAXERS
The old invoice - voucher system needs to be reviewed and updated urgently before June 1, 2025;
Enterprises with unclear addresses and changing representatives many times need to review the risk of being flagged by tax authorities;

Enterprises issuing invoices to foreign customers need to retrain their staff on the new tax refund invoice process.

🛡️ DO NOT TAKE INVOICES - DOCUMENTS LIGHTLY
Circular 32/2025/TT-BTC is not only a change in the legal corridor, but also a strong signal from tax authorities in tightening transparent management and preventing invoice fraud.

Invoices are no longer just procedures, but legal "evidence", a shield to protect businesses from the risks of inspection - punishment - collection.

🔍 What do you need to be ready?
✅ Review and update internal electronic invoice system✅ Tax accounting training with experts knowledgeable about new laws✅ Participate in Audit Care Vietnam's updated training programs