VAT Refund Dossier Checklist for Investment Projects: Get It Right the First Time
An FDI project has spent tens of billions of dong on machinery and construction during the investment phase. When it comes to preparing the VAT refund dossier for the investment project, the accountants discover missing non-cash payment proof for a series of invoices above 5 million, several EPC contracts lacking acceptance appendices, and VAT returns for the last three periods with wrong line items. Result: the dossier is returned, everything must be redone, and the refund cash flow is delayed by months. The checklist below helps businesses review all 18 items before filing — so you file once, not twice. (See also the general guide on VAT refunds for FDI companies for the broader refund-conditions context.)
Table of contents
- 1. How to use this checklist
- 2. Group A — Project legal papers
- 3. Group B — Input VAT evidence
- 4. Group C — Deduction, offset records and the refund request
- 5. Group D — Filing and post-filing follow-up
- 6. Seven mistakes that get dossiers returned
- 7. Condensed checklist table
- 8. Frequently asked questions (FAQ)
- 9. When to work with a lawyer
- Language versions
- References
1. How to use this checklist
The checklist has 18 items in 4 groups, each presented as: What to do (the specific task), Why (the basis and why the tax authority requires it), How (how to do it), Watch out (common errors). Print the checklist, assign one person overall responsibility, tick each item when done, and keep all scans/copies in the group order. The group order is also the preparation priority: project legal papers first (they establish refund eligibility), then input documents (the most labor-intensive part), then returns and the refund request, and finally filing and follow-up.
2. Group A — Project legal papers
A1. Investment Registration Certificate (IRC) and amendments
What to do: Collect the valid IRC of the project plus all IRC amendment documents (if any): changes to capital scale, schedule, objectives, or project location.
Why: The IRC proves the project is a “new/expansion investment project” under investment law — the threshold condition in Article 15(2) of the 2024 VAT Law. Without a valid IRC, the tax authority has no basis to establish refund eligibility.
How: Check the National Investment Information System or company records; if the IRC has been amended several times, prepare a summary table of amendments with effective dates for easy cross-checking.
Watch out: Where a project is split into multiple investment phases or components, each phase/component must be clearly reflected in the IRC or amendment documents — this is usually the tax authority’s first question.
A2. Enterprise Registration Certificate (ERC) and tax registration
What to do: Prepare the valid ERC, the tax registration certificate (or tax code notice), and confirmation that the enterprise applies the VAT credit method.
Why: Only businesses paying VAT under the credit method qualify for VAT refunds on investment projects. This is a taxpayer-status condition, independent of the project condition.
How: Extract tax registration information from the e-tax system; for a newly established project company, verify the registered tax calculation method from the very first filing period.
Watch out: A business on the direct method that wants to switch to the credit method must complete the conversion before the refund-claim period — you cannot file for a refund while requesting the switch.
A3. Investment policy decision/approval (where applicable)
What to do: Collect the investment policy decision or approval document from the competent authority, for projects subject to it under the 2025 Investment Law.
Why: For projects requiring policy approval, this is the founding document establishing the project’s legality; without it, the IRC may be deemed insufficient.
How: Check the list of projects subject to policy approval under the 2025 Investment Law; keep both the original and any approval amendments.
Watch out: Not every project needs this document — verify your project’s category to avoid wasting time obtaining an unnecessary document or, worse, missing a mandatory one.
A4. Project land and construction legal papers
What to do: Collect the land lease/land allocation decision, construction permits, and acceptance minutes for completed components (if any) related to the investment project.
Why: These papers prove the project is genuinely in the investment phase and that investment costs are real, tied to specific sites and components — the basis for the tax authority to cross-check input invoices and documents.
How: List documents by construction component; each component should have the trio: land legality — construction permit — acceptance (if accepted).
Watch out: Projects leasing ready-built workshops (no construction) still need the lease contract and handover minutes — don’t leave this group blank just because “nothing was built”.
A5. Confirm the project is not in an excluded category (charter capital, conditional business lines)
What to do: Prepare proof that: (i) the business has fully contributed its registered charter capital at the time of filing (capital contribution statements, bank confirmations); (ii) for conditional business lines: valid licenses/certificates of eligibility, or confirmation that the project, still in the investment phase, is not yet subject to licensing.
Why: Article 15(2)(b) of the 2024 VAT Law excludes refunds where the business has not fully contributed its charter capital or does not satisfy/maintain conditional business-line requirements at filing time — a common but unexpected ground for refusal among FDI companies.
How: Reconcile actual contributed capital against the charter capital on the ERC; if contributing on a schedule, complete the final tranche before filing the refund dossier. For conditional business lines, list all licenses with their validity periods.
Watch out: Investment projects in natural resource and mineral extraction (except oil and gas exploration, prospecting and field development projects under Article 15(2)(a)), and investment projects manufacturing products that are extracted natural resources or minerals processed into other products (Article 5(23)), are not entitled to a refund; any undeducted input VAT is instead carried forward to the next period — so stop preparing the refund dossier and switch to the carry-forward approach.
3. Group B — Input VAT evidence
B1. Input VAT invoices for purchased goods and services
What to do: Collect all input VAT invoices arising during the investment phase: machinery and equipment, materials, construction and installation, consultancy, and other goods/services serving the project.
Why: Valid invoices are the direct basis for determining deductible/undeducted input VAT — the central figure of the refund dossier.
How: Export the input invoice listing by tax period; reconcile with filed VAT returns; flag adjusted/replaced invoices to exclude them or explain them clearly.
Watch out: Invoices for goods/services not serving the investment project (e.g. costs of ongoing business operations) must be separated — mixing them is a common error that makes the tax authority doubt all figures.
B2. Economic contracts, appendices, acceptance and liquidation minutes
What to do: For each major invoice group (construction, equipment procurement, EPC), prepare the original contract, appendices adjusting value/volume, volume acceptance minutes and contract liquidation minutes (if liquidated).
Why: The tax authority cross-checks the “three legs”: contract — acceptance — invoice — payment. Missing one leg breaks the evidentiary chain.
How: Build a contract file for each contract: contract + appendices + acceptance + invoices + payment proof, with consistent numbering.
Watch out: Foreign-currency contracts need exchange-rate clauses and conversion documents; contracts with foreign contractors need contractor-tax returns and payment proof — otherwise the costs may be disallowed.
B3. Non-cash payment proof (the VND 5 million threshold)
What to do: For every invoice for goods/services of VND 5 million or more (VAT included), prepare bank payment proof: payment orders, bank statements, debit/credit advices.
Why: Article 26 of Decree 181/2025/ND-CP requires non-cash payment proof for purchases of VND 5 million or more for input VAT to qualify for deduction — without deduction eligibility there is no refund.
How: Match each invoice ≥ 5 million against bank statements; build a 1-to-1 reconciliation table (invoice no. — payment doc no. — amount — payment date). For debt-offset payments, add the offset minutes signed by both parties.
Watch out: Cash payment for an invoice ≥ 5 million is a “fatal” error — it cannot be fixed by later explanation. Review this item first in Group B.
B4. Detailed ledgers of deductible input VAT
What to do: Prepare the detailed ledger of deductible VAT, and the summary of input VAT arising — deducted — still undeducted, accumulated from the start of the investment phase to the refund-claim period.
Why: This is the “general ledger” proving the claimed refund figure is correctly and fully computed, with no duplication across periods.
How: Export from the accounting software, signed by the chief accountant and the legal representative; figures must match filed VAT returns 100% — even a one-dong difference needs explanation.
Watch out: If the enterprise runs both an investment project and ongoing business operations, input VAT accounting for the two must be separated from the start; separating commingled accounting afterwards is nearly impossible to clean up.
B5. VAT offset records against ongoing operations (if any)
What to do: If the enterprise has ongoing business operations alongside the investment project, prepare returns and documents proving the offset of the project’s undeducted VAT against tax payable from ongoing operations.
Why: Article 15(2) of the 2024 VAT Law requires offsetting first — only the remaining unoffset amount of VND 300 million or more qualifies for refund. Without proving the offset step, the refund dossier is deemed ineligible.
How: Build a period-by-period offset table: project undeducted input VAT — tax payable from ongoing operations = remaining refund claim; attach the VAT returns of ongoing operations.
Watch out: The 300 million threshold applies to the post-offset amount. Many businesses wrongly compute it on total undeducted input, getting the claim rejected at the first review.
4. Group C — Deduction, offset records and the refund request
C1. VAT returns for the investment-phase periods
What to do: Collect all VAT returns (and supplementary returns, if any) for the tax periods from when project input VAT first arose to the refund-claim period.
Why: Returns are the legal record of accumulated undeducted tax; the tax authority reconciles returns against accounting books and invoice listings.
How: Download filed versions with tax authority confirmation from the e-tax system; if there are supplementary returns, arrange them chronologically and explain the adjustment reasons.
Watch out: Any missing period return must be filed first — a refund dossier missing one period in the chain will be sent back for completion, wasting time.
C2. The VAT refund request document
What to do: Draft the refund request using the current prescribed form, stating: taxpayer information, the investment project, the claim period, the claimed amount, and how the refund should be received (which bank account).
Why: This document initiates the refund procedure — everything in the dossier serves the figures and commitments stated here.
How: Use the current form (check the e-tax system or ask the managing tax authority directly); figures must match the claim-period return and the Group B summary exactly.
Watch out: A wrong receiving account number is a silly but real error — double-check account details; the account holder name must match the claimant enterprise.
C3. Summary table of claimed VAT
What to do: Build a detailed summary: input VAT arising by period — deducted/offset — still undeducted — claimed amount, with clear formulas.
Why: The summary is the “map” letting tax officers quickly verify the whole dossier; a clear summary significantly shortens processing time.
How: Present periods vertically in chronological order; each row references the corresponding return and invoice listing; signed by the preparer, chief accountant and legal representative.
Watch out: Don’t submit just the total — the tax authority needs to see how that figure was built period by period.
C4. Commitments and explanations on dossier accuracy
What to do: Prepare a written commitment on the dossier’s truthfulness and accuracy; for special points (adjusted invoices, debt offsets, multi-phase projects), draft detailed explanations with supporting documents.
Why: Proactively explaining “sensitive” points moves the dossier faster than waiting for the tax authority to request point-by-point explanations.
How: List likely questions in advance (from similar dossiers’ experience or this checklist), one concise paragraph per point with document references.
Watch out: Explanations must be consistent with return and book figures — contradictions between the explanation and the figures invite deeper scrutiny.
5. Group D — Filing and post-filing follow-up
D1. Identify the correct receiving tax authority
What to do: Confirm the tax authority directly managing the enterprise and the specific unit receiving refund dossiers (which division, which officer if possible).
Why: Filing with the wrong tax authority is a basic but recurring error, especially for enterprises with projects in a different province from the head office.
How: Check the enterprise’s tax management assignment notice; call to confirm before filing; for e-filing, verify the correct sub-item and receiving authority on the system.
Watch out: Keep the filing receipt (stamped paper copy or electronic confirmation) — it anchors processing deadlines and complaints if the dossier stalls.
D2. Track progress and prepare supplementary explanations
What to do: Keep a dossier log: filing date, handling officer, meetings, supplementation/explanation requests and response deadlines.
Why: Investment-project refund dossiers almost always go through at least one round of supplementary explanation; being ready shortens each round.
How: Assign a single contact for the tax authority; keep numbered copies of all incoming/outgoing documents.
Watch out: Answer supplementation requests within the given deadline — lateness can get the dossier returned or require refiling from scratch.
D3. Reconcile the refund decision and receive the money
What to do: When the refund decision arrives, reconcile the granted amount against the claim; verify the money reaches the account in the right amount and on time.
Why: Decisions may grant a partial refund (disallowing some items); the business needs to know exactly what was disallowed and why, to act further.
How: Prepare an internal reconciliation; for disallowed parts, assess whether to complain or adjust in a later period; book the refund correctly.
Watch out: Businesses may complain against a partial refund or refusal under the Tax Administration Law — but weigh the grounds carefully before complaining.
D4. Archive the refund dossier as required
What to do: Archive the entire refund dossier (as filed + working papers + the refund decision) for the statutory retention period for accounting and tax documents.
Why: Refund dossiers may be re-inspected in later years; lost documents mean losing the ability to defend an accepted position.
How: Keep both paper and scanned copies, arranged in this checklist’s A–D group order; maintain an archive index.
Watch out: When changing chief accountants or accounting service providers, handing over the refund dossier index is mandatory — many businesses lose track of dossiers at this handover.
6. Seven mistakes that get dossiers returned
- Cash payment for invoices of VND 5 million or more — unfixable; see B3.
- Mixing invoices not serving the investment project into the claim — see B1.
- Claiming the full amount without offsetting against tax payable from ongoing operations — see B5.
- Refund request figures not matching returns and books — see C2, C3.
- Missing IRC amendments after project scale/schedule changes — see A1.
- Foreign contractor contracts lacking contractor-tax proof — see B2, and details in foreign contractor tax in contracts with foreign partners.
- Filing after the project has been completed for over 01 year — the claim right has lapsed with no remedy; see also issues in terminating an investment project.
7. Condensed checklist table
| # | Item | Done |
|---|---|---|
| A1 | Valid IRC and amendment documents | ☐ |
| A2 | ERC, tax registration, credit-method confirmation | ☐ |
| A3 | Investment policy decision/approval (if applicable) | ☐ |
| A4 | Land, construction and acceptance papers | ☐ |
| A5 | Confirm not in an excluded category (charter capital, conditional business lines) | ☐ |
| B1 | Project-serving input VAT invoices (other operations separated) | ☐ |
| B2 | Contracts + appendices + acceptance + liquidation per package | ☐ |
| B3 | Non-cash payment proof for invoices ≥ VND 5 million | ☐ |
| B4 | Detailed ledgers and input VAT summary matching returns | ☐ |
| B5 | Offset calculation against ongoing operations (300M threshold post-offset) | ☐ |
| C1 | Complete VAT returns for all periods (plus supplements if any) | ☐ |
| C2 | Refund request on the correct form, figures matching | ☐ |
| C3 | Period-by-period summary of claimed tax | ☐ |
| C4 | Accuracy commitment + explanations of special points | ☐ |
| D1 | Correct receiving tax authority identified, receipt kept | ☐ |
| D2 | Tracking log, single contact, on-time supplementary responses | ☐ |
| D3 | Refund decision reconciled, money received, disallowed parts handled | ☐ |
| D4 | Dossier archived as required | ☐ |
8. Frequently asked questions (FAQ)
What document groups make up a VAT refund dossier for an investment project?
Four groups: (1) project legal papers (IRC, ERC, investment policy approval); (2) input VAT evidence (invoices, contracts, non-cash payment proof from VND 5 million); (3) deduction/offset records and filings (period VAT returns, accounting books, the refund request); (4) post-filing follow-up (receipts, explanatory submissions). See the checklist in this article for each item.
From what amount is non-cash payment proof required?
Under Article 26 of Decree 181/2025/ND-CP, goods and services purchased from VND 5 million (VAT included) must be paid with non-cash payment proof for the input VAT to qualify for deduction — and therefore for refund.
Where is a VAT refund dossier for an investment project filed?
With the tax authority directly managing the enterprise. Confirm the receiving authority under the current management assignment before filing to avoid filing with the wrong authority.
What should be done if the dossier is returned or additional documents are requested?
Read the return/supplementation notice carefully, check each point against this checklist, and supplement correctly and fully within the given deadline. Never resubmit the same dossier without fixing the cited points.
Can a completed project still claim a VAT refund?
Yes, if filed within 01 year from the project completion date. The completion date is the date revenue first arises (excluding trial-run revenue, financial income and raw-material liquidation). After 01 year, the right to claim a refund for the investment phase lapses.
9. When to work with a lawyer
- Reviewing the project’s refund eligibility from the project setup stage (IRC, tax method, project classification).
- Designing document, payment and accounting processes from the start so the refund dossier is “clean” at filing time.
- Reviewing the full dossier before filing, spotting weaknesses the tax authority will question.
- Drafting explanatory submissions and dealing with the tax authority during processing.
- Complaining against a partial refund decision or a refusal.
FLAT Law Firm supports FDI businesses through the entire VAT refund dossier lifecycle — from document design to receiving the refund. Contact hotline 0988424851.
Language versions
References
- 2024 VAT Law (48/2024/QH15), effective 01/7/2025
- Law 90/2025/QH15 amending tax laws, effective 01/7/2025
- Law 149/2025/QH15 amending the Law on Value Added Tax, effective 01/01/2026 (does not amend Article 15(2))
- Decree 181/2025/ND-CP detailing the VAT Law, effective 01/7/2025
- Circular 69/2025/TT-BTC guiding Decree 181/2025/ND-CP
- 2025 Investment Law (143/2025/QH15), effective 01/3/2026
- 2025 Tax Administration Law (108/2025/QH15), effective 01/7/2026