Circular No. 32/2025/TT-BTC issued by the Ministry of Finance, effective from June 1, 2025, replaces the entire Circular 78/2021/TT-BTC. This Circular provides detailed instructions on the implementation of invoices and documents according to the Law on Tax Administration and related decrees, and adds many new regulations to strengthen management, facilitate taxpayers and ensure digital transformation requirements.
Electronic invoices have new symbols
One of the highlights is the specific regulation on electronic invoice model symbols and electronic invoice symbols. Accordingly, the model symbol is numbered from 1 to 9 corresponding to invoices such as VAT, sales invoices, e-commerce invoices, invoices integrated with taxes, fees, charges, etc.
The invoice symbol consists of 6 characters, including letters showing the invoice type (T - registration; L - issued by the tax authority; M - from the cash register; CTTC - for financial lease...). This helps to clearly classify the purpose and form of invoice use, serving management work.
The Circular also adds detailed regulations on the authorization of electronic invoices. The seller may authorize a third party to make an invoice if it meets the conditions and does not stop using the invoice. The form of mandate must have a written contract/agreement, notify the tax authority, and be publicized for consumers to understand.
New regulations on business households and money calculation invoices
Circular 32 continues to require business households and individuals with a revenue of VND1 billion/year or more to use electronic invoices generated from cash registers. However, business households that have registered and used before June 1, 2025 will continue to use the old form without having to convert.
The Circular allows businesses with multiple business activities to simultaneously use multiple types of invoices: cash registers for direct retail activities, and electronic invoices with codes or without codes for other activities.
Tightening the criteria for high-risk taxpayers, forcing them to switch to invoices with codes
An important new point is the regulation on compulsory conversion from un encrypted invoices to encrypted invoices for high-risk taxpayers. The tax authority will notify, and taxpayers must convert within 10 working days.
The Circular identifies 5 risk criteria such as: the representative related to the violating organization, unclear address, signs of buying and selling invoices, or violating tax regulations. The Tax Department is authorized to determine taxpayers at very high risk according to the assessment index in each period.
Specific instructions for financial leasing activities
Circular 32/2025/TT-BTC for the first time guiding details on how to make invoices in financial leasing activities. If the enterprise leases all the input VAT to the lessee right after the first payment, the invoice should specify the transfer tax section with the "CTTC" code.
In case the contract is terminated early and the property is revoked, the lessee must adjust the deducted VAT amount. When the property is resold, the financial leasing organization must issue an invoice as usual.
Supplementing integrated invoice models, invoices for foreigners
Circular issuing a sample of value-added invoices and tax refund declarations for foreigners. The invoice has three parts: part A is prepared by the seller, part B is checked by customs, part C is paid by the bank. This is the first time the Ministry of Finance has specifically regulated the content, expression and digital signature requirements of all three parties.
In addition, there are also integrated invoice models: VAT and tax receipts, sales invoices and tax receipts, serving the goal of simplifying documents and increasing transparency in budget collection management.
Tightening standards for organizing the provision of electronic invoice services
The Circular adds many strict conditions for organizations providing electronic invoice solutions and invoice data storage and transmission services. These units must have financial, technical capacity, specialized personnel in information technology, and backup data centers at least 20km away...
For organizations providing services to receive, transmit and store invoice data, they must have a minimum deposit or bank guarantee of VND 5 billion to prevent risks and be responsible for compensation for damages if violations occur.
The Tax Departments of localities will publicly post the list of qualified organizations on the tax industry's administrative procedure settlement information system for taxpayers to look up and use appropriate services.
Handling transfers and incorrect invoices
The Circular clearly stipulates the transition cases when changing from old invoices to electronic invoices according to Decree 70/2025/ND-CP. In case the invoice has been issued according to Decree 51/2010/ND-CP or 04/2014/ND-CP but the error is discovered, the seller must make a written agreement with the buyer and issue a replacement electronic invoice.
The Circular also allows the continued use of old printed invoices and receipts if the content is still suitable and the symbol matches the new regulations.
