VI What are the guidelines for the content of trade discount invoices according to Decree 70 in Official Letter 953/DAN-QLDN2? What is the taxable value for value-added tax in the case of trade discounts? How many principles are there for creating, managing, and using electronic invoices according to current regulations? Let’s explore more with Pham Consult!
Guidelines on the content of commercial discount invoices according to Decree 70 in Official Document 953/DAN-QLDN2
On August 26, 2025, the Da Nang City Tax Department received Document No. 34/2025/CV-G4S from G4S Petroleum Investment Joint Stock Company requesting guidance on the content of commercial discount invoices according to Decree 70/2025/ND-CP. In response to the Company’s tax policy inquiry, the Da Nang City Tax Department, in its Official Letter 953/DAN-QLDN2 of 2025, provides the following opinion:
Based on point d, clause 6, Article 10 of Decree 123/2020/ND-CP, the following is stipulated:
Contents of the invoice:
- Name, unit of measurement, quantity, unit price of goods and services; total amount excluding value-added tax, value-added tax rate, total value-added tax amount according to each tax rate, total value-added tax, total payment amount including value-added tax.
- d) In cases where a business applies a trade discount or promotion to customers as prescribed by law, the trade discount or promotion must be clearly shown on the invoice. The determination of the taxable value for value-added tax (the amount excluding value-added tax) in cases where a trade discount or promotion is applied shall be carried out in accordance with the provisions of the value-added tax law.
Based on Clause 2, Article 14 of Decree 181/2025/ND-CP, the following is stipulated:
Principles for determining the taxable value for value-added tax
- In cases where a business applies a trade discount to customers (if any), the taxable value for value-added tax is the selling price after the trade discount applied to the customer, excluding value-added tax.
Based on point b, clause 4, Article 19 of Decree 123/2020/ND-CP, amended by clause 13, Article 1 of Decree 70/2025/ND-CP, the regulations on replacing and adjusting electronic invoices are as follows:
Replacing and adjusting electronic invoices
- Invoices for adjusting electronic invoices already issued in some cases are as follows:
- b) In cases where the trade discount is based on the quantity or sales volume of goods and services, the discount amount for goods and services sold shall be adjusted on the sales invoice of the last purchase or the next period, ensuring that the discount amount does not exceed the value of goods and services recorded on the invoice of the last purchase or the next period, or an adjustment invoice shall be issued accompanied by a list of the invoices to be adjusted, the amount, and the adjusted tax. The list shall be kept at the unit and presented when requested by the tax authority or competent state agency. Based on the adjustment invoice, the seller and buyer declare adjustments to sales revenue, purchase revenue, output tax, and input tax in the period in which the adjustment invoice is issued.
According to the above regulations, the City Tax Department has the following response: If the company issues a discount invoice that does not exceed the value of goods in the last order, the invoice must fully reflect the value of goods before the discount and the trade discount value in accordance with Article 10 of Decree 123/2020/ND-CP.
If the unit incurs a trade discount after the invoice has been issued (end-of-period discount based on sales volume or contract), the unit must issue an adjustment invoice on the sales invoice for goods or services of the last purchase or the subsequent period, ensuring that the discount amount does not exceed the value of goods or services recorded on the invoice of the last purchase, along with a list of the invoices needing adjustment, the amount, and the adjusted tax.
What is the VAT taxable price in the case of a trade discount?
The VAT taxable price in the case of a trade discount is stipulated in Article 14 of Decree 181/2025/ND-CP as follows:
Principles for determining the VAT taxable price
- The taxable price for goods and services specified in this Section:
- a) Includes surcharges and additional fees collected in addition to the price of goods and services that the business receives.
- b) Excludes income not related to the sale of goods or provision of services by the business: income from monetary compensation (including compensation for land and assets on land when land is reclaimed according to the decision of a competent state agency), bonuses, third-party claims from insurance activities, amounts collected on behalf of others, fees from state agencies for performing collection and disbursement activities on behalf of state agencies, and financial income.
- In cases where a business applies a trade discount to customers (if any), the value-added tax (VAT) calculation price is the selling price after the trade discount, excluding VAT.
- In cases where a business has already calculated value-added tax but the taxable price changes according to the conclusion of a competent state agency in accordance with relevant laws, the taxable price shall be determined according to the conclusion of the competent state agency.
Accordingly, if a business applies a trade discount for customers (if any), the value-added tax taxable price is the selling price after the trade discount, excluding value-added tax.
How many principles are there for the creation, management, and use of electronic invoices according to current regulations?
According to Article 90 of the 2019 Law on Tax Administration, the principles for the creation, management, and use of electronic invoices are as follows:
– When selling goods or providing services, the seller must create an electronic invoice to give to the buyer in a standard data format and must record all the contents as prescribed by tax law and accounting law, regardless of the value of each sale of goods or provision of services. – If the seller uses a cash register, the seller must register to use electronic invoices generated from the cash register with an electronic data transfer connection to the tax authority.
– The registration, management, and use of electronic invoices in transactions involving the sale of goods and provision of services must comply with the regulations of the law on electronic transactions, accounting law, and tax law.
– The tax authority’s issuance of a code on the electronic invoice is based on the information provided by the business, economic organization, other organization, household business, or individual business on the invoice. The business, economic organization, other organization, household business, or individual business is responsible for the accuracy of the information on the invoice.
