On the Ministry of Finance's Information Portal, Ms. N.T.A.T in Lam Dong reflected:
Point c, Clause 1, Article 9 of Decree No. 320/2025/ND-CP of the Government detailing a number of articles and measures to organize and guide the implementation of the Enterprise Income Tax Law.
This Decree stipulates expenditures with non-cash payment vouchers for cases of purchasing goods, services and other payments each time with a value of 05 million VND or more.
Non-cash payment vouchers are made in accordance with the provisions of legal documents on value-added tax.
So let me ask, other payments each time with a value of 05 million VND or more here include all payments that the enterprise makes in the course of business operations or are just non-cash payments currently regulated in Article 26 of Decree No. 181/2025/ND-CP.
The Tax Department in Lam Dong answers this question as follows:
Clause 1, Article 9 of Decree No. 320/2025/ND-CP dated December 15, 2025 of the Government detailing a number of articles and measures to organize and guide the implementation of the Enterprise Income Tax Law. Accordingly, expenditures are deducted when determining taxable income.
Except for non-deductible expenses specified in Article 10 of this Decree, enterprises are entitled to deduct expenses when determining taxable income if they meet the conditions in points a, b and c below:
The actual expenditure incurred related to the production and business activities of the enterprise, including expenditure deducted as a percentage calculated on the actual expenditure incurred during the tax period related to the enterprise's research and development activities.
The expenditure has sufficient invoices and documents as prescribed by law.
Expenditures with non-cash payment vouchers for the purchase of goods, services and other payments each time have a value of 05 million VND or more. Non-cash payment vouchers are made in accordance with the provisions of legal documents on value-added tax.
Based on Article 26 of Decree No. 181/2025/ND-CP dated July 1, 2025 of the Government detailing the implementation of a number of articles of the Value Added Tax Law as follows:
Non-cash payment vouchers:
Business establishments must have non-cash payment vouchers for purchased goods and services (including imported goods) from 05 million VND or more including value-added tax. In which:
Non-cash payment documents are documents proving non-cash payments according to the provisions of Decree No. 52/2024/ND-CP dated May 15, 2024 of the Government on non-cash payments, except for documents where the buyer deposits cash into the seller's account.
Some specific cases as prescribed in point b, clause 2, Article 14 of the Law on Value Added Tax include:
In case goods and services are purchased according to the method of compensation between the value of goods and services purchased and the value of goods and services sold, borrowed goods, and this payment method is specifically stipulated in the contract, there must be a record of data comparison and confirmation between the two parties on the compensation payment between goods and services purchased and goods and services sold, borrowed goods. In case of debt compensation through a third party, there must be a record of debt compensation of the three parties as a basis for tax deduction.
In case of purchasing goods and services from a taxpayer with a value of less than 05 million VND but buying many times in the same day with a total value of 05 million VND or more, tax is only deductible for cases with non-cash payment documents.
Based on the above regulations, in case a business incurs purchases of goods, services and payment expenses related to production and business activities with a payment value of 05 million VND or more each time, it must have non-cash payment vouchers, which are determined to be expenses deducted when calculating corporate income tax.
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