Scenario: Mr. Phuc’s online shop sells 500 orders a day. At month-end, the accountant issues one consolidated invoice for the whole month “to save effort”. During a tax inspection, the shop is fined for wrong invoice timing. Meanwhile, an invoice mistakenly shows VND 500 million instead of 50 million. What does current law say?
Invoice timing: at delivery, not at payment
Decree 123/2020/ND-CP on invoices and documents (amended by Decree 70/2025/ND-CP, dated 20 March 2025, effective 1 June 2025) sets the principle: e-invoices must be issued when the sale occurs or service completes — when goods are delivered and ownership transfers — regardless of payment collection. For online sales, invoicing time is at customer delivery (or handover to the carrier per agreement), not when the platform settles funds at month-end. Month-end consolidated invoicing is wrong-timing invoicing and draws administrative invoice penalties. Decree 70/2025 clarifies: for tax-authority-coded e-invoices, issuance time is when the seller digitally signs and submits to the tax authority’s system for coding; signing must occur by the next working day after issuance at the latest.
Handling invoice errors: adjust or replace
Erroneous e-invoices may not be casually deleted; the law requires adjustment invoices (stating the increase or decrease against the original) or replacement invoices, with a written agreement between seller and buyer (except where unilateral handling is permitted). Adjustment and replacement invoices must reference the original invoice’s number and symbol. For the 50-versus-500-million error above, the shop must issue a downward adjustment of 450 million, with both parties digitally signing the minutes. All adjustments and replacements transmit data to the tax authority — which can reconcile the full history — so issuing a fresh invoice “to be done with it” will be detected.
E-commerce-specific notes
First, customer-refused orders showing “returned” on carrier or platform systems: the transaction is not a sale — no invoice, no taxable revenue — but keep return-status evidence for explanation. Second, household businesses with annual revenue of VND 1 billion or more must use e-invoices generated from cash registers connected to the tax authority (Decree 70/2025/ND-CP) — for direct-to-consumer sales. Third, taxable revenue follows delivery timing even where platform settlement slips to the next month — settlement timing does not shift the taxable revenue period.
Frequently asked questions
Must invoices be issued when retail customers don’t take them?
Yes. Sellers must issue e-invoices for every sale of goods or services, even where buyers don’t take them. Invoices remain in the seller’s system with data transmitted to the tax authority.
What is the fine for wrong-timing invoices?
Administrative penalties under tax and invoice sanction rules; fines scale with the nature and number of violating invoices, plus possible remedial measures.
An error found after the coded invoice went to the tax authority?
Still handle via adjustment or replacement invoices. Never unilaterally cancel a coded invoice without an adjustment or replacement, as its data already sits in the tax authority’s system.
