Refunding money to customers, business households may push themselves into invoice errors

Song Anh |

Returning money and canceling applications is not wrong, but if the handling of electronic invoices is not in accordance with regulations, business households may still be penalized.

In current business operations, especially for retailers, F&B, fashion and selling goods through social networks, customers changing their minds, canceling orders or requesting refunds occur frequently. Many cases of undelivered goods, short delivery, incorrect sample delivery or customers not receiving goods.

Many business households believe that when transactions are not completed or money has been refunded to customers, they do not need to care about invoices. However, with the mechanism of tax management based on electronic invoices, the method of handling invoices in these situations has been quite strictly regulated by law.

When to cancel, when to adjust invoices

According to Decree 123/2020/ND-CP on invoices and documents, which has been amended and supplemented by Decree 70/2025/ND-CP, the handling of invoices when errors arise or transactions are no longer distinguished according to each specific case.

In case the invoice has been created but has not been sent to the buyer and the transaction is not detected or canceled, the seller is allowed to cancel the invoice in the correct order on the electronic invoice system.

Conversely, if the invoice has been sent to the buyer, even if the goods have not been delivered or the transaction is cancelled afterwards, the business household is not allowed to arbitrarily delete or cancel the invoice. At that time, the seller must make an adjusted invoice or a replacement invoice, depending on the nature of the error, to reflect the cancellation of the transaction or refund.

Clearly distinguishing between the time "invoices have been sent" and "invoices have not been sent" is a key factor determining legal handling.

Self-deleting invoices, risk of being fined

In fact, many business households when encountering the situation of canceling applications often delete invoices on the software, delete archived files or skip transactions because they think "it's okay if the money hasn't been collected yet". This approach poses great risks.

According to Decree 125/2020/ND-CP, amended and supplemented by Decree 310/2025/ND-CP, the act of handling invoices improperly, including arbitrarily canceling, deleting or not adjusting the issued invoices, may be subject to administrative sanctions.

In addition, if incorrect invoice processing leads to not fully storing invoice data, business households may also be determined to have violated the obligation to store electronic invoices according to legal regulations.

Money refund does not mean "erasing" invoice obligations

A common mistake is that if money has been refunded to customers, the automatic invoice is no longer valid. In fact, electronic invoices are legal documents reflecting transactions at the time of occurrence. Money refund is only a post-transaction processing step, not losing the obligation to process invoices in accordance with regulations.

In case of the entire amount of money, business households need to make a reduced adjustment invoice or a replacement invoice to show that the transaction is no longer valid, instead of ignoring or deleting the old invoice.

Correct handling helps ensure that revenue, tax and invoice data match, avoiding risks when management agencies compare the system.

Handling correctly to reduce tax risks

From the tax management perspective, refunds and cancellations are not violations. Risks only arise when business households process invoices improperly or let invoice data not reflect the actual transaction.

Strictly complying with the order of canceling, adjusting or replacing invoices according to Decree 123/2020/ND-CP (amended and supplemented) helps business households:

- Avoid administrative penalties for invoices;

- Avoid being recorded revenue in the wrong period;

- Reduce the risk of being retroactively taxed or having to pay late taxes.

In the context of tax management based on electronic data, invoices not only need to be made correctly but also handled correctly when fluctuations arise. For business households, understanding the regulations on canceling invoices, refunding money and processing invoices is an important factor for stable operation and limiting legal risks.

Song Anh
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