On July 1, 2025, the Government of Vietnam issued Decree 181/2025/ND‑CP (the “Decree”) implementing key provisions of the 2024 VAT Law (Law No. 48/2024/QH15). The Decree introduces stricter conditions for claiming input VAT credit, including the following core requirements:
1. Non‑Cash Payment for Purchases ≥ VND 5 Million
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Business expenses valued at VND 5 million or more (inclusive of VAT) require proof of non-cash payment to be eligible for VAT credit.
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The proof must comply with Decree 52/2024/ND‑CP, while deposit transfers from buyer to seller’s account are explicitly not accepted as valid proof.
2. Special Transaction Arrangements
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Barter or netting: Must be contractually specified, with offset agreements and written reconciliation.
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Debt offsetting: Requires prior loan agreement and transfer evidence.
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Third-party payments: Must be authorized in writing; payee must be a legally compliant entity.
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Payments in securities: Require a prior written trading agreement.
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Any balance ≥ VND 5 million after offsets must be paid non-cash
3. Specific Case Treatments
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Payments to the State Treasury on behalf of another party may qualify for input VAT credit when acting as an enforcement measure.
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Deferred or installment purchases ≥ VND 5 million require contract, invoice, and non-cash proof; temporary VAT credit allowed but must be adjusted if proof isn’t provided by due date.
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Employee reimbursed payments via non-cash means are eligible if internal financial policies are followed.
4. Exceptions
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Imports under VND 5 million, gifts, donations, or samples received from abroad are exempt from non-cash proof requirement.
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However, multiple purchases from the same seller on the same day that cumulatively reach VND 5 million must comply with the non-cash rule.
Complying with Decree 181 ensures your eligibility for input VAT credit and avoids potential disputes during tax audits. It affects key areas such as procurement, investment disbursements, employee reimbursements, and complex financial arrangements. Businesses should immediately align internal processes, contracts, and payment methods to meet the enhanced documentation and non-cash criteria.
