In the context of increasingly strict tax management, determining and implementing the correct time of invoice issuance plays a key role in controlling the compliance risk of enterprises. Current laws allow some specific cases to issue backdated invoices to suit the specific characteristics of business activities, but require strict compliance with the deadlines and conditions. This article summarizes 7 cases where backdated invoices are allowed to be issued according to the provisions of Decree 123 / 2020 / ND-CP , and Decree 70 / 2025 / ND-CP, helping businesses proactively manage compliance, limit violations and optimize financial and accounting operations.
1. Time of invoice issuance
📌 Time of invoice for sale of goods
The time of invoicing for the sale of goods (including the sale and transfer of public assets and the sale of national reserves) is time of transfer of ownership or right to use goods for, buyer, regardless of whether the money has been collected or not.
📌 Invoice time for service provision
The time of invoice for service provision is time of completion of service provision (including providing services to foreign organizations and individuals) regardless of whether the money has been collected or not: In case the service provider prepaid or while providing services, the time of invoice is the time to collect money (Not including cases of collecting deposits or advances to ensure the performance of contracts for providing services: Accounting, auditing, financial and tax consulting; valuation; survey, technical design; supervision consulting; construction investment project preparation)
In case of multiple deliveries or handover of each service item or stage, each delivery or handover must include an invoice for the corresponding volume and value of goods and services delivered.
📌 Time of invoice issuance for construction and installation activities
For construction and installation activities, the time of invoice issuance is the time of acceptance and handover of the project, project items, and completed construction and installation volume, regardless of whether the payment has been collected or not.
📌 Invoice time for real estate business
For real estate business organizations, infrastructure construction, house construction for sale and transfer:
- In case ownership and usage rights have not been transferred: If payment is collected according to the project implementation progress or the payment collection progress stated in the contract, the time of invoice issuance is the payment collection date or according to the payment agreement in the contract.
- In case of transfer of ownership or usage rights: The time of invoice issuance shall comply with the provisions of Clause 1 of this Article.
📌 Time to issue invoices for passenger transport business by taxi
For passenger transport business by taxi using fare calculation software according to the provisions of law: at the end of the trip, the enterprise or cooperative operating passenger transport business by taxi using fare calculation software shall issue an electronic invoice to the customer and at the same time transfer the invoice data to the tax authority according to the provisions.
📌 Time to issue invoices for medical examination and treatment facilities
For medical examination and treatment facilities that use medical examination and treatment management software and hospital fee management software, each medical examination and treatment transaction and the performance of imaging, x-ray, and testing services will have a printed receipt (hospital fee or medical examination and testing fee) and saved on the information technology system. If the customer (person coming for medical examination and treatment) does not need an invoice, at the end of the day, the medical examination and treatment facility will use the medical examination and treatment information and information from the receipt to compile and create an electronic invoice for the medical services performed during the day. In case the customer requests an electronic invoice, the medical examination and treatment facility will create an electronic invoice and give it to the customer.
Medical examination and treatment facilities shall invoice the social insurance agency at the time the social insurance agency pays and settles medical examination and treatment costs for people with health insurance cards.
⚠️ Note: Invoice time is the time of completion of sales, provision of services, acceptance and handover of completed volume … regardless of whether the money is received or not.
2. Cases of late invoice issuance
📌 Summary:
| STT | Type | Invoice date |
|---|---|---|
| 1 | Export of goods (including export processing) | Slowest no later than the next business day from the date the goods are cleared through customs |
| 2 | Sales and service provision in large quantities, arising frequently, need data reconciliation between businesses selling goods, providing services and customers, partners | At the latest the 07th of next month month of supply. |
| 3 | Telecommunications and information technology services | Slowest 02 months from the date of the reconciliation service. |
| 4 | Buy air freight services through website | No later than Next 05 days from the date the air transport service document is issued on the website and e-commerce system. |
| 5 | Providing air transport and insurance services through agents | Invoicing maximum 10 days of the following month when reconciliation is complete. |
| 6 | Casino business, electronic games with prizes | Invoice within 01 days from the date of revenue recognition. |
📌 Export of goods (including export processing)
For export of goods (including export processing), the time of issuing e-commerce invoices, electronic value-added invoices or electronic sales invoices is determined by the seller but at the latest no later than the next working day from the date the goods are cleared through customs according to customs regulations.
Base: Clause 1 Article 9 Decree 123/2020/ND-CP (amended and supplemented by Decree 70/2025/ND-CP).
📌 Sales and service provision in large quantities, arising frequently, need data reconciliation
Invoice time: When the reconciliation is completed between businesses selling goods, providing services and customers, partners, but the slowest not too the 07th of next month month of service or not too 07 days from the end of the convention period agreed between the parties concerned.
Applicable to services:
- Support air transport, supply jet fuel to airlines and support rail and water transport;
- Electricity supply (except for the subjects specified in Point h Clause 4);
- Television, television advertising;
- E-commerce;
- Post and delivery (including agency, collection/payment services);
- Telecommunications (including value-added telecommunications services);
- Logistics;
- Information technology (except for the case specified in Point b Clause 4) is sold in certain periods;
- Banking (except lending activities), international money transfer;
- Securities, electronic lottery;
- Road use fee collection between investors and toll service providers;
- Other cases as directed by the Minister of Finance.
Base: Point a, Clause 4, Article 9 Decree 123/2020/ND-CP (amended and supplemented by Decree 70/2025/ND-CP).
📌 Telecommunication and information technology services
For telecommunications services (including value-added telecommunications services), information technology services (including payment intermediary services used on telecommunications and information technology platforms), it is required to reconcile connection data between service business establishments. The time of invoice issuance is the time of completion of data reconciliation on service fees according to the economic contract between service business establishments, but no later than 2 months from the month the connection service fee arises.
In case of providing telecommunications services (including value-added telecommunications services) through the sale of prepaid cards, collecting roaming charges when customers register to use the service without the customer's request to export VAT invoices or do not provide name, address, tax identification number, at the end of each day or periodically in a month, the service business establishment shall jointly make a VAT invoice recording the total revenue arising from each service the buyer does not provide. take the invoice or do not provide the name, address, tax identification number.
Base: Point b, Clause 4, Article 9 Decree 123/2020/ND-CP (amended and supplemented by Decree 70/2025/ND-CP).
📌 Purchase air transport services via website/e-commerce system
The time for issuing invoices for cases where business organizations purchase air transport services exported through websites and e-commerce systems is established according to international practice at the latest. no later than 05 consecutive days from the date the air transport service document is issued on the website system and e-commerce system.
Base: Point d Clause 4 Article 9 Decree 123/2020/ND-CP.
📌 Providing air transport and insurance services through agents
In the case of providing air transport services and insurance services through agents, the time of invoice issuance is the time of completion of data reconciliation between the parties but at the latest no later than the 10th of the month following the month of occurrence.
Base: Point k Clause 4 Article 9 Decree 123/2020/ND-CP.
📌 Casino business, electronic games with prizes
For casino and electronic game business activities, the latest time to issue electronic invoices is 01 day from the end of the revenue determination date, at the same time, casino and electronic game businesses transfer data recording the amount of money collected (from exchanging conventional currency for players at the counter, at the table and the amount collected at the electronic game machine) minus the amount of money exchanged for players (from players winning prizes or players not using all of them) according to Form 01/TH-DT Appendix IA issued with this Decree to the tax authority at the same time as transferring electronic invoice data. The date of determining revenue is the period from 0:00 to 23:59 on the same day.
Base: Point r Clause 4 Article 9 Decree 123/2020/ND-CP (supplemented by Decree 70/2025/ND-CP).
Complying with regulations on the time of issuing electronic invoices helps businesses avoid the risk of penalties, while building a transparent accounting and tax control system. Understand correctly - Do correctly will help businesses minimize risks, improve compliance and protect business interests during tax inspections and audits.