VI Should export goods be used in e-commerce units? When is the time to issue e-commerce invoices? Let’s find out more with Pham Consult!
Should export goods be used in e-commerce units?
According to the provisions of Article 8 of Decree 123/2020/ND-CP (supplemented by Point c, Clause 5, Article 1 of Decree 70/2025/ND-CP), it is stipulated as follows:
Types of invoices
Invoices specified in this Decree include the following types:
– E-commerce invoices are invoices applicable to organizations, enterprises, and individuals (exporters) that export goods and provide services abroad and the exporter meets the conditions for transferring commercial invoice data electronically to the tax authority. E-commerce invoices must meet the content requirements as prescribed in Article 10 of this Decree and the regulations on standard data formats of the tax authority as prescribed in Article 12 of this Decree.
In case the exporter does not meet the conditions for electronically transmitting commercial invoice data to the tax authority, the exporter can choose to issue an electronic value-added invoice or an electronic sales invoice.
Thus, an electronic commercial invoice is one of the current types of invoices.
However, an electronic commercial invoice is only applicable to organizations, enterprises, and individuals (hereinafter referred to as exporters) that export goods and provide services abroad and the exporter meets the conditions for electronically transmitting commercial invoice data to the tax authority.
In case the exporter does not meet the conditions for electronically transmitting commercial invoice data to the tax authority, the e-commerce invoice option must not be used but must be selected: (1) to issue an electronic value-added tax invoice or (2) to issue an electronic sales invoice in accordance with regulations.
When is the time to issue an e-commerce invoice?
According to the provisions of Clause 1, Article 9 of Decree 123/2020/ND-CP (amended by Point a, Clause 6, Article 1 of Decree 70/2025/ND-CP):
Time to issue an invoice
The time of invoice issuance for the sale of goods (including the sale, transfer of public assets and sale of national reserve goods) is the time of transfer of ownership or right to use the goods to the buyer, regardless of whether the money has been collected or not.
For the export of goods (including export processing), the time of issuance of e-commerce invoices, electronic value-added invoices or electronic sales invoices is determined by the seller, but no later than the next working day from the date the goods are cleared through customs in accordance with the provisions of the law on customs.
Thus, the time for issuing an e-commerce invoice for exported goods (including export processing) is determined by the seller himself, but no later than the next working day from the date the goods are cleared through customs in accordance with the provisions of the law on customs.
How is the format of an e-commerce invoice regulated?
According to the provisions of Article 8 of Decree 123/2020/ND-CP (supplemented by Point c, Clause 5, Article 1 of Decree 70/2025/ND-CP), an e-commerce invoice meets the content requirements as prescribed in Article 10 of Decree 123/2020/ND-CP and the regulations on standard data formats of tax authorities as prescribed in Article 12 of Decree 123/2020/ND-CP.
Therefore, e-commerce invoices must meet the tax authority’s common data standard format for e-invoices in Article 12 of Decree 123/2020/ND-CP (amended by Clause 9, Article 1 of Decree 70/2025/ND-CP) as follows:
– The e-invoice format is a technical standard that specifies the data type and data length of information fields serving the transmission, storage and display of e-invoices. The e-invoice format uses the XML text formatting language (XML is an abbreviation for the English phrase “eXtensible Markup Language” created for the purpose of sharing electronic data between information technology systems)
– The electronic invoice format consists of two components: a component containing electronic invoice business data and a component containing digital signature data. For electronic invoices with tax authority codes, there is an additional component containing data related to the tax authority code.
– Organizations and enterprises selling goods and providing services when transferring electronic invoice data to tax authorities by direct submission must meet the following requirements:
+ Connect to the General Department of Taxation via a leased channel or MPLS VPN Layer 3 channel, including 1 main transmission channel and 1 backup transmission channel. Each transmission channel has a minimum bandwidth of 5 Mbps.
+ Use Web Service or Message Queue (MQ) with encryption as the connection method.
+ Use SOAP protocol to package and transmit data.
– Electronic invoices must display the full and accurate contents of the invoice to ensure that they do not lead to misunderstandings so that buyers can read them electronically.
