VAT Refund in Vietnam for Exporters With Accurate Books

A VAT refund in Vietnam for exporters arises when, in a month or quarter, the company has exported goods or services and its uncredited input VAT is VND 300 million or more, under Article 15(1)(a) of the Law on Value-Added Tax. The amount of a VAT refund in Vietnam may not exceed 10% of export revenue in the refund period. The company must also pay VAT under the credit method, keep books and documents as required, hold a bank account under its tax code, and its input VAT must meet the crediting conditions.

This article is for business owners, chief accountants and finance managers of exporting companies, including foreign-owned companies in Ho Chi Minh City and nearby provinces. It focuses on what the company controls: the books, the documents and the preparation before filing. It does not cover refunds for investment projects or on dissolution. Sources were checked on 04/11/2026.

Conditions for a VAT Refund in Vietnam on Exports

The conditions for a VAT refund in Vietnam fall into two groups: conditions on the tax amount and conditions on the company. The table below summarises the main points.

Condition	What it requires	Legal basis
Exports in the period	Exported goods or services in the month or quarter	Article 15(1)(a), Law on VAT
Threshold	Uncredited input VAT of VND 300 million or more	Article 15(1)(a), Law on VAT
Cap	The refund may not exceed 10% of export revenue in the refund period; the excess is carried forward to determine the next refundable amount	Article 15(1)(b), Law on VAT
Exclusion	Goods imported and then exported to another country, other than materials imported to produce or process goods for export	Article 29(1)(b), Decree 181/2025/ND-CP (consolidated text)
Tax method and books	Pay VAT under the credit method; prepare and keep accounting books and documents as required	Article 15(9)(a), Law on VAT
Bank account	Hold a deposit account at a bank under the tax code	Article 15(9)(a), Law on VAT
Crediting conditions	Meet Article 14(2) and not fall under Article 14(3) of the law	Article 15(9)(b), Law on VAT

For a company that both exports and sells domestically, the calculation is more complex. The company must account separately for input VAT used for exports. If it cannot, the input VAT for exports is determined by the ratio of export revenue to total taxable revenue in the refund period. After offsetting against the VAT payable on domestic sales, this amount must still be VND 300 million or more. A VAT refund in Vietnam therefore depends directly on how the accountant separates the figures from the start.

The refund period runs from the tax period in which uncredited input VAT arose and remained unrefunded continuously up to the period of the claim. The accountant should track this amount period by period so that the amount claimed can be explained.

The Documents Behind a VAT Refund in Vietnam

The file sent to the tax authority is short, but the heavy part is the documents kept at the company. Under Article 46(1)(a) of Circular 89/2026/TT-BTC, the file for a VAT refund in Vietnam on exports consists of VAT return form 01/GTGT with the refund claim item completed and refund appendix form 01-8/GTGT.

The documents behind the return are set out in Articles 18 and 27 of Decree 181/2025/ND-CP. For a VAT refund in Vietnam, the checklist for one export shipment includes:

• The contract for selling or processing goods or supplying services with the foreign party, and the export entrustment contract if any.
• The invoice for the goods or services sold.
• The customs declaration that has completed customs procedures, unless a declaration is not required under customs law.
• Non-cash payment documents: the transfer from the importer’s account to an account in the exporter’s name, and the bank credit note.
• The packing list, bill of lading and cargo insurance documents, if any.
• For purchases: the VAT invoice or the import VAT payment document, and non-cash payment documents for purchases of VND 5 million or more including tax, except the special cases in Article 26 of the decree.

Deferred payment must be agreed in the contract or an appendix, and a non-cash payment document must exist when payment falls due. Payment by a third party, offsetting of debts and sale of receivables each have their own conditions under Article 27. These cases should be checked before the revenue is included in a VAT refund in Vietnam.

Process and Timelines for a VAT Refund in Vietnam

The tax authority classifies each claim for a VAT refund in Vietnam as refund first or inspection before refund. The table below sets out the milestones in Decree 252/2026/ND-CP and Circular 89/2026/TT-BTC.

Step	Timeline	Legal basis
Notice accepting or rejecting the file	03 working days from receipt of the file	Article 31(1)(a), Decree 252/2026/ND-CP
Refund first	No later than 06 working days from the acceptance notice, excluding time for explanations and supplements	Article 31(2)(a), Decree 252/2026/ND-CP
Inspection before refund	No later than 10 working days from the conclusion or handling decision after the on-site inspection, excluding time for explanations and supplements	Article 31(2)(b), Decree 252/2026/ND-CP
Post-refund inspection	For refund-first files, under risk management, within 05 years from the refund decision	Article 53(1), Circular 89/2026/TT-BTC

A first refund claim for exports is subject to inspection at the company’s premises before refund, under Article 30(1)(a) of Decree 252/2026/ND-CP and Article 48(1)(a) of Circular 89/2026/TT-BTC. Files assessed as high risk, and files within 02 years after the company was penalised for tax evasion, are also in this group. A company making its first VAT refund in Vietnam should prepare for an inspection team at its premises, not only the return.

A Hypothetical Example of a VAT Refund in Vietnam

Hypothetical example: an export-only company has export revenue of VND 5 billion in the refund period and eligible uncredited input VAT of VND 620 million.

Line	Amount (VND million)
Uncredited input VAT	620
VND 300 million threshold check	Met
10% cap on export revenue: 5,000 × 10%	500
Maximum refund claim	500
Amount above the cap	120

The VND 120 million is carried forward to the next tax period to determine the next refundable amount. The example assumes no domestic revenue and that every document meets the conditions. The detailed calculation of a VAT refund in Vietnam follows the Ministry of Finance’s guidance.

Why a VAT Refund in Vietnam Often Gets Stuck

The law has no list of reasons for rejecting a VAT refund in Vietnam. The groups below are our professional view, each linked to one of the conditions above.

Issue	Why it matters	What to check
Money not received from the right party into the right account	Article 27 requires a transfer from the importer to an account in the exporter’s name, except in conditional cases	Payer name on the credit note against the contract
Problems with input invoices	Input VAT must meet Article 14(2)	Invoices, non-cash payment, supplier status
Revenue on customs declarations, invoices and books does not match	The 10% cap is based on export revenue in the refund period	A reconciliation by customs declaration
Export and domestic input VAT cannot be separated	It affects the input VAT attributed to exports	Tracking codes in the books, allocation method
Goods imported and then exported included in the claim	This case is excluded	Origin of the goods in each shipment
Contract and appendices do not reflect the payment terms	Deferred payment, third parties and offsetting must be written into the contract	Payment terms against actual cash flows

Accurate books are what these lines have in common. A reconciliation by shipment, covering the contract, invoice, customs declaration, credit note and revenue entry, answers most questions raised when a VAT refund in Vietnam is inspected.

Preparing for a Post-Refund Inspection of a VAT Refund in Vietnam

Receiving a VAT refund in Vietnam is not the end. Under Article 53(2) of Circular 89/2026/TT-BTC, if a post-refund inspection finds that the amount refunded was incorrect, the tax authority issues a decision to recover it, imposes penalties and charges late-payment interest where applicable. If the taxpayer finds the error itself, Article 54(2) requires a supplementary return, repayment of the excess refund and the corresponding late-payment interest.

One situation in a VAT refund in Vietnam is specific to exporters. Under Article 54(3), if the company has received a refund but the buyer returns the exported goods, the company must file a supplementary return and repay the corresponding refund and late-payment interest, without an administrative tax penalty.

Article 41(5) of the Law on Accounting requires documents used directly for bookkeeping, accounting books and annual financial statements to be kept for at least 10 years, unless another law provides otherwise. In practice, keep one file per refund period so that it can be found quickly during an inspection.

6 Mistakes to Avoid in a VAT Refund in Vietnam

In our professional view, these are the mistakes most worth checking.

• Looking only at input VAT and forgetting the 10% cap on export revenue.
• Forgetting to offset VAT payable on domestic revenue before testing the VND 300 million threshold.
• Treating a valid invoice as enough, without checking payment documents for purchases.
• Receiving export proceeds through another account or a third party not provided for in the contract.
• Claiming a VAT refund in Vietnam for the first time without preparing for an on-site inspection.
• Sorting documents after filing, instead of reconciling shipment by shipment during the period.

FAQs About VAT Refund in Vietnam

Can a company exporting services get a VAT refund in Vietnam? Article 15 of the Law on VAT applies to exported goods and services. For services, the company needs a contract and non-cash payment documents under Article 18 of Decree 181/2025/ND-CP, and the service must qualify for the 0% rate.

What if the amount is below VND 300 million? The uncredited VAT continues to be carried forward to the next month or quarter under Article 14(1)(dd) of the law.

Can a quarterly filer claim a VAT refund in Vietnam? Yes. The law provides for refunds by month or quarter, in line with the company’s filing period.

How long does a VAT refund in Vietnam take? The timelines in the table above are the tax authority’s deadlines and exclude time for explanations and supplements. We make no commitment on actual timing.

Is the process the same in every province? The rules apply nationwide. The receiving tax office depends on the authority that manages the company.

How Pham Consult Supports a VAT Refund in Vietnam

Pham Consult has pages on documentation and request for tax refund, tax consulting services and accounting services. If your company is building up input VAT and considering a VAT refund in Vietnam, start by reviewing the books and documents shipment by shipment. The actual scope is confirmed in the service contract.

To discuss, please book an accounting review or call +84 909 660 105. Let us know the input VAT being carried forward, recent export revenue and whether the company has claimed a refund before.

Legal sources were checked on 09/11/2026. This article is for general information only and does not constitute legal, tax or accounting advice; regulations may change after the date of publication, so please seek professional advice for your specific situation before making any decision.