📌 Summary:
| Case | Non-cash payment (NCP) | Requirements for supporting documents |
|---|---|---|
| Usually, common, normal | Bank transfer (according to Decree 52/2024/ND-CP) |
Bank transfer documents. Cash deposits into the seller's account are not accepted. |
| Feature 1 | Offsetting the value between goods and services |
Minutes of data comparison and confirmation between the two parties. If through a third party, it is necessary Minutes of debt offset of three parties. |
| Feature 2 | Offset of loan debt | Written loan/borrowing contract previously established; remittance certificate from the lender's account to the borrower's account. |
| Feature 3 | Third party authorization payment |
Specific provisions in written contract The third party must be a legally operating organization/individual. |
| Feature 4 | Payment by stocks, bonds | Written sales contract previously established. |
| Feature 5 | Enforcement according to State Decision | Remittance documents into a third party account at the State Treasury according to the Decision of the State agency. |
| Feature 6 | Buy on credit, pay in installments |
Sales contract, VAT invoice, commercial transaction documents (if payment is due), if not due, temporary deduction is still allowed. |
| Feature 7 | Import under 05 million VND, import of goods as gifts, samples does not require payment | No need for non-cash payment documents for purchased goods and services |
| Feature 8 | Payment authorization by employee |
Payment by TTKTM when authorizing payment on behalf of others according to financial/internal regulations and TTKTM refund.
|
In the context of the value-added tax (VAT) deduction mechanism continuing to tighten on documents and payment methods, establishing and storing correct non-cash payment documents becomes a prerequisite for businesses to be eligible for valid tax deductions. Current regulations require businesses to prove payment cash flow through valid channels to be eligible for input VAT deductions. This article provides guidance on 10 cases and document requirements as a basis for determining VAT deductions based on Decree 181 / 2025 / ND-CP October 01, 07.
I. What is cashless payment?
From January 01, 07, Law on Value Added Tax 2024 No. 48/2024/QH15 officially takes effect, detailing the conditions for input VAT deduction. Specifically, Point b Clause 2 Article 14 regulations:
"There are non-cash payment documents for purchased goods and services, except for some special cases as prescribed by the Government;"
To provide specific guidance on this regulation, on July 1, 2025, the Government issued Decree 181 / 2025 / ND-CP guidance on the Law on Value Added Tax. In which, Article 26 Item 2 Decree regulating invoices for goods and services purchased each time from 05 million VND or more (VAT included) must have proof of non-cash payment to deduct input VAT.
💡 Abolish the regulation on invoice value of 20 million VND of the 2013 amended VAT Law.
According to the Article 26, Clause 1 of Decree 181/2025/ND-CP:
Non-cash payment vouchers are Documents proving non-cash payment as prescribed in Decree No. 52/2024/ND-CP May 15, 2024 of the Government on cashless payments, except for the buyer's payment documents credit to the seller's account.
⚠️ Note: Not accepted The buyer documents the payment directly to the seller's account.
Decree No. 52 / 2024 / ND-CP Decree No. 15/2024/ND-CP dated May 15, 2024 of the Government on non-cash payment stipulates: Non-cash payment means (hereinafter referred to as payment means) are means issued by payment service providers, financial companies licensed to issue credit cards, payment intermediary service providers providing e-wallet services and used by customers to make payment transactions, including: check, payment order, payment authorization, collection, collection authorization, bank card (including: debit cards, credit cards, prepaid cards), electronic wallet and other means of payment as prescribed by the State Bank.
II. 08 special cases and specific document requirements
According to the Point 2 Article 26 Decree 181/2025/ND-CP stipulates 08 special cases According to the provisions of Point b, Clause 2, Article 14 of the Law on Value Added Tax, VAT deductions are applied, including:
1. Clearing the value between goods and services
In case of goods and services purchased by the method of payment offsetting between the value of purchased goods and services and the value of sold goods and services, or borrowing goods, and this payment method is specifically stipulated in the contract, there must be Minutes of data reconciliation and confirmation between the two parties on clearing payments between purchased goods and services and sold goods and services, and borrowed goods. In case of debt offset through a third party, there must be three-party debt offset minutes as a basis for tax deduction.
2. Offsetting debt of loans and borrowings; offsetting through a third party
In case of goods and services purchased by debt offset method such as borrowing or lending money; offsetting debt through a third party, and this payment method is specifically stipulated in the contract, there must be loan contract in written form previously established and have money transfer document from the lender's account to the borrower's account For loans and borrowings in cash, including cases of offsetting the value of purchased goods and services with the amount of money that the seller supports the buyer or asks the buyer to pay on their behalf.
3. Third-party authorized payment
In case the purchased goods and services are paid for by authorization through a third party for non-cash payment (including cases where the seller requests the buyer to make non-cash payment to a third party designated by the seller), the payment by authorization or payment to a third party designated by the seller must be specifically stipulated in the contract. contract in written form and the third party is a organizations or individuals operating under the provisions of law.
4. Payment by stocks and bonds
In case of goods and services purchased by payment for goods and services by stocks or bonds, and this payment method is specifically stipulated in the contract, there must be a previously established written sales contract.
5. Enforcement according to State Decision
In case of purchased goods and services paid for by non-cash method into a third party account opened at the State Treasury to enforce by means of collecting money and assets held by other organizations and individuals (according to the Decision of competent state agencies).
Requirement: Have documents for transferring money to a third-party account at the State Treasury according to the enforcement decision of the state agency; the deduction level corresponds to the amount transferred to this account.
6. Installment purchase from 05 million VND
For goods and services purchased on credit or installments with a value of 05 million VND or more, business establishments shall base on: contract purchase of goods and services in writing, value added tax invoice , and non-cash payment voucher of goods and services purchased on deferred or installment payments to deduct input value added tax. In case there is no non-cash payment document because the payment time according to the contract or contract appendix has not yet arrived, the business establishment is still allowed to deduct input value added tax.
In case the payment deadline has not yet come according to the contract or the Contract Appendix, temporarily deductible. If the due date comes without a non-cash document, the business must adjusted declaration Tax deducted from the tax period in which payment obligations arise under the contract or contract appendix.
7. Imports under 05 million VND, imports of goods as gifts and samples do not require payment.
In case the value of imported goods and services each time is less than 05 million VND, goods and services purchased each time according to invoices are less than 05 million VND at prices including value added tax, and in case the business establishment imports goods as gifts, presents, samples without payment from organizations and individuals abroad, there is no need for non-cash payment documents for purchased goods and services.
8. Payment authorization by employee
In case goods and services purchased to serve the production and business activities of goods and services subject to value added tax are authorized to individual is an employee of a business establishment cashless payment financial regulations or internal regulations of the business, then the business pay back workers in cashless forms input VAT is deductible.
Only applicable to individual is an employee of a business establishment
⚠️ Note:
In case of purchasing goods and services of a taxpayer with a value of less than 05 million VND but Multiple purchases on the same day with a total value of 05 million VND or more tax deduction is only allowed in the case of have non-cash payment vouchers.
Effective VAT deduction is the result of a well-designed document management process: standardizing payment terms right from the contract, operating standard clearing/authorization, keeping full track of bank documents and debt reconciliation, and controlling transaction thresholds to properly apply non-cash payment conditions. Enterprises should maintain a transparent document lifecycle (establishing - approving - storing - periodically reconciling), digitizing data for quick retrieval when needed, and conducting internal reviews before the declaration/settlement period. This approach helps minimize compliance risks, preserve deduction rights and raise financial - accounting operation standards towards discipline, transparency and data control.
📑 Excerpt from the law:
- VAT Law 2024 – Article 14. Input VAT deduction.
- Decree 181 / 2025 / ND-CP – Article 26. Non-cash payment documents.
- Decree 52 / 2024 / ND-CP – Regulations on non-cash payments.