Non-cash payment evidence under the Value-Added Tax Law (Law No. 48/2024/QH15)
2025/11/27
- Le Thi Hoang Dung
Introduction
From July 1, 2025, with the official enforcement of Law No. 48/2024/QH15 on Value-Added Tax, the Ministry of Finance has promulgated Decree No. 181/2025/ND-CP (hereinafter “Decree 181”) providing detailed guidelines on practical matters.
In particular, the conditions related to non-cash payments are one of the notable points.
Compared to previous regulations, the new provisions are presented more specifically and clearly regarding practical matters, which is expected to make it easier for taxpayers to proceed with procedures.
This article explains the non-cash payment receipts based on the new regulations effective from July 1, 2025, as a follow-up to the report on “Non-Cash Payment Receipts” posted on the IGL website on July 16, 2024.
1. Non-Cash Payment Receipts
1.1 Non-Cash Payment Receipts
Non-cash payments, according to Government Decree No. 52/2024/ND-CP dated May 15, 2024, refer to transactions in which organizations or individuals make payments or remittances using transfer, checks, payment orders via banks, payment delegations, bank cards, electronic wallets, or other payment methods recognized by the State Bank of Vietnam.
Organizations providing non-cash payment services include the State Bank of Vietnam, banks, branches of foreign banks, credit cooperatives, microfinance institutions, and public postal service providers.
In this Government Ordinance No. 181, what specifically constitutes “non-cash payment receipts” has been clarified.
Non-cash payment receipts refers to the proof that payment was made using a non-cash payment service or payment instrument as specified in Government Ordinance No. 52/2024/ND-CP dated May 15, 2024.
However, evidence of payment when the buyer deposits cash directly into the seller’s account is excluded.
Based on the above, according to Government Decree 181, the payment ceiling for which submission of non-cash payment receipts is not required has been lowered from the previous 20 million dong to 5 million dong.
Specifically, for the purchase of goods and services totaling 5 million dong or more including value-added tax, it is stipulated that if taxpayers do not have non-cash payment receipts, they will not be allowed to deduct the purchased value-added tax.
1.2 Cases to be aware of that are not considered cashless payments
As stated above, remittances and collection/payment procedures via banks are considered non-cash payment receipts; however, it should be noted that evidence of cash deposited by the buyer into the seller’s account is not recognized as non-cash payment receipts for tax purposes.
Furthermore, organizations that provide cashless payment services are interpreted as organizations established and operated under Vietnamese law; therefore, payment methods provided by organizations such as PayPal or Alipay, which are established under foreign laws and do not have a legal entity or branch in Vietnam, are not recognized as cashless payment services for tax purposes.
Additionally, when a taxpayer purchases goods or services multiple times on the same day and each transaction is less than 5 million dong but the total amount is 5 million dong or more, the deduction of input value-added tax is only permitted for transactions with non-cash payment evidence.
2. Some special cases recognized as non-cash payments
2.1 In the case of set-off of debts and claims
The method of offsetting debts and claims is often seen between parent and subsidiary companies or within the same group.
Compared to the old regulations, there are no significant changes, but for tax purposes, non-cash settlements are only recognized in the following two cases.
・In cases where the value of purchased goods or service purchase fees are offset against the value of sold goods/services or loaned goods (conditions must be explicitly stated in the contract to allow for debt and claim offsetting, with a debt and claim matching document and set-off agreement).
・When offsetting the value of purchased goods or service purchase payment with a loan, or offsetting it with debts through a third party (conditions must explicitly state in the prior loan agreement that debt and credit can be offset, and there must be remittance evidence from the lender).
In addition, if there is a remaining balance exceeding 5 million dong after the offsetting of debt and claims, it is necessary to have non-cash settlement evidence for the remaining amount.
2.2 In the case of employee reimbursement payments
In practice, it is common for employees to pay expenses on behalf of the company and then have the company reimburse them later.
The old Value Added Tax Act did not have provisions regarding this matter and only the Corporation Tax Act prescribed regulations; however, the new Value Added Tax Act has added specific guidelines, ensuring consistency.
For advance payments to be recognized as non-cash transactions, the following conditions must be met.
・It is stipulated in the financial regulations or internal rules that employees are authorized to make payments on behalf of the company.
・When employees make advance payments, they use non-cash payment methods.
・When the company settles accounts with employees, a non-cash payment method should also be used.
2.3 In the case of installment purchase and deferred payment purchase
When purchasing goods or services through installment or deferred payment purchases with a purchase price of 5 million dong or more, the buyer can deduct input value-added tax based on the sales contract for the goods or services and the value-added tax invoice.
However, if the non-cash payment proof is not provided by the payment deadline specified in the contract or its annex, the buyer must adjust by decreasing the already deducted input value-added tax.
Additionally, according to the official letter No. 434/VLO-QLDN2 from the VinLong Province Tax Department, it is important to note that if a company obtains a non-cash payment voucher after the deferred payment deadline specified in the contract or contract annex, the deduction of input value-added tax based on that voucher will not be allowed.
2.4 Other cases
In addition to the three cases above, the following situations are also recognized as non-cash payments.
・When the buyer makes a payment to the national treasury based on a compulsory enforcement decision by a government agency for the collection related to the seller’s money or assets.
・In cases where settlement is made through stocks, corporate bonds, or non-cash settlements involving a third party (provided that all involved parties have clearly agreed upon the terms in writing, such as in a contract, regarding the settlement method).
In conclusion
This article describes the conditions for non-cash payments based on Article 48 of the Value Added Tax Law.
Traditionally, regarding corporate tax, Circular 78/2014/TT-BTC stipulated that “non-cash payment vouchers shall comply with the provisions of the Value Added Tax Law.” However, the Corporate Tax Law 2025, promulgated on June 14, 2025 and effective from October 1 of the same year, only broadly stipulates “non-cash payment vouchers according to the provisions of the law,” without providing detailed guidelines.
While the new tax law has come into effect, detailed guidelines regarding its enforcement have not yet been issued at this time.
It is recommended that companies continue to monitor information to correctly understand the new regulations on non-cash payments from the perspectives of both value-added tax and corporate tax, and to respond appropriately.
References：
・Value Added Tax Law No. 48/2024/QH15
・Government Decree 181/2025/ND-CP (Promulgated on July 1, 2025)
・Government Decree No. 52/2024/ND-CP (Promulgated on May 15, 2024)
・Notification 18/2024/TT-NHNN (promulgated on June 28, 2024)
・Report titled “Tax Considerations Regarding the Conditions of Non-Cash Payment Evidence” published on the IGL websitehttps://www.i-glocal.com/report/240716/
・Official Document No. 434/VLO-QLDN2 of the Vinlon Province Tax Department
・Corporate Tax Law No. 67/2025/QH15
This article was translated using Yarakuzen.
