FDI Enterprises Buying Digital Services From Foreign Providers by International Card: Cost Deduction Vouchers and Contractor Tax

A Google Ads charge, a SaaS subscription or a data purchase paid on a company international card looks like a consumer transaction, but where the buyer is a Vietnamese enterprise it is a purchase of services from a foreign contractor — carrying foreign contractor tax duties and document conditions for the cost to be deductible.

Governing Instruments

The decisive line: whether the supplier is tax-registered in Vietnam

Under the e-commerce tax administration framework in Circular 80/2021/TT-BTC, a foreign supplier without a permanent establishment in Vietnam that carries on e-commerce or digital services business with organisations and individuals in Vietnam must register, declare and pay tax through the dedicated e-portal for foreign suppliers. Major platforms and suppliers (Google, Meta, Microsoft and others) have registered and pay tax in Vietnam under this mechanism. The consequence for the buyer: where the supplier is registered and self-declares, the Vietnamese enterprise no longer withholds foreign contractor tax on that payment.

Conversely, where the supplier is not tax-registered in Vietnam, the duty returns to the buyer: the Vietnamese enterprise using the service must declare, withhold and remit on behalf the foreign contractor taxes (value added tax and corporate income tax) on the supplier taxable revenue. The contractor tax framework changed fundamentally from 12 March 2026: the corporate income tax part of Circular 103/2014/TT-BTC was repealed, and the new framework comprises the Law on Corporate Income Tax 67/2025/QH15, Decree 320/2025/ND-CP and Circular 20/2026/TT-BTC — under which the CIT ratio on revenue is 5% for services and 10% for royalties (Clause 3, Article 12 of Decree 320/2025), with the VAT portion for services at 5%.

Deduction documents where the supplier issues no Vietnamese invoice

A foreign supplier issues no Vietnamese e-invoice, so the deduction file must be built systematically around the deductibility conditions of corporate income tax law: the expense is actually incurred and related to the business; lawful invoices and documents are in place; and payment is non-cash for expenses of VND 5 million or more. For digital services the file comprises: the contract or terms of service plus the enterprise account confirmation; the supplier commercial invoice or service usage report; payment evidence — card statement or bank remittance order; and the contractor tax payment receipts where the enterprise remits on behalf.

Payment by an international card issued to the enterprise through a Vietnamese bank still leaves a full banking trail: the card statement is valid payment evidence when it can be tied to the supplier invoice and the enterprise account. The common violation is not the card channel itself but staff using personal cards to pay for company services — the document chain then breaks (the payer is not the enterprise), the cost is easily disallowed, and reimbursement and personal income issues arise on top.

Application Analysis

On foreign exchange, buying services from abroad is a current-account transaction: FX law allows organisations in Vietnam to pay for imported services through lawful payment channels, including international cards issued by banks, provided the transaction is genuine and documented for bank and regulator review when needed. Card payment is not a violation merely because it is fast and bypasses a traditional remittance order; the risk sits in transactions whose service nature cannot be evidenced (buying “accounts” through unclear intermediaries) or payments exceeding limits or outside the purposes registered for the corporate card.

In settlement practice, the tax authority works this area as a chain: determine whether the supplier is registered, then whether the enterprise withheld correctly where the supplier is unregistered, then test the deduction documents. Enterprises should maintain a register of digital suppliers in use with each supplier Vietnamese tax-registration status (checkable on the tax authority portal) and refresh it each settlement period, because supplier registration status changes over time — a supplier unregistered last year may register this year, and the buyer withholding duty changes with it.

Recommended Actions

Build a register of all foreign digital services in use, tagging each supplier tax-registration status in Vietnam and refreshing it periodically.
For unregistered suppliers: set a process to declare, withhold and remit contractor tax before payment, under Decree 320/2025 and Circular 20/2026.
Standardise payment through corporate cards and bank channels; end personal-card payment for company services and clear legacy reimbursements.
Keep the full file per expense: terms of service, invoice, usage report, payment statement, contractor tax receipts — enough to trace a transaction years later.

Frequently Asked Questions

Must an enterprise buying foreign digital services paid by international card declare contractor tax?

It depends on the supplier registration status. If the foreign supplier has registered, declared and paid tax in Vietnam through the e-portal for foreign suppliers under Circular 80/2021/TT-BTC, the purchasing enterprise does not withhold contractor tax. If the supplier is unregistered, the Vietnamese enterprise must declare, withhold and remit on behalf the foreign contractor VAT and CIT under the current framework (from 12 March 2026: Law 67/2025, Decree 320/2025, Circular 20/2026).

Which documents replace invoices so the cost of buying digital services is deductible?

The substitute file comprises: the contract or terms of service with the enterprise account confirmation; the commercial invoice or service usage report issued by the supplier; payment evidence via bank or the corporate card statement showing payment to the correct supplier; and contractor tax payment receipts where the enterprise remits on behalf. Plus the general conditions: the expense is actually incurred for the business, and non-cash payment applies to amounts of VND 5 million or more.

Does paying a digital supplier by company card breach foreign-exchange or payment rules?

No, provided the transaction is a genuine payment for imported services, made through an international card issued to the enterprise by a bank in Vietnam, with full documents evidencing the service nature. Current-account transactions may be paid through lawful channels including cards. Violations arise in other situations: using a personal card for company services and breaking the document chain, buying services through intermediaries where the actual supplier cannot be identified, or paying outside the corporate card purposes registered with the bank.

If the foreign digital supplier is already tax-registered in Vietnam, must the enterprise still withhold?

No. Once the supplier has registered and self-declares and pays tax through the foreign-supplier e-portal, the supplier tax duty is performed directly with the Vietnamese tax authority and the buyer no longer withholds contractor tax on that payment. The enterprise must still keep the transaction and payment documents for its cost to be deductible, and should check the supplier registration status at the time of payment because that status can change.