From June 1, 2025, Circular 32/2025/TT-BTC of the Ministry of Finance officially took effect, providing detailed instructions on the application of electronic invoices for some types of services with specific characteristics, requiring data verification before making invoices.
These are uncommon cases in normal retail activities but appear frequently in transactions between businesses and businesses and organizations.
Services that need to be compared - will be invoiced later
According to Article 6 of Circular 32, cases where invoices are allowed to be issued after consulting with customers and partners include:
- derivatives (applied according to the provisions of the law on credit, securities, trade, VAT)
- Industrial food supply services
- Services of the goods exchange department
- Credit information services
- Business service of passenger transport by taxi (for customers who are organizations or enterprises)
The units providing these services must still prepare electronic invoices in accordance with regulations, but this is done after completing the data comparison process with the buyer.
What should financial leasing enterprises pay attention to when issuing invoices?
Also according to the guidance in Circular 32, financial leasing organizations when leasing assets subject to value-added tax (VAT) must have:
- Input VAT invoice (if purchasing domestic assets)
- Or a certificate of VAT payment for import (if imported assets)
When issuing an output invoice, the total VAT amount must match the input, the tax rate is marked as "CTTC".
If the property is not subject to tax or does not have a tax certificate, VAT cannot be recorded on the output invoice.
Handling invoices when financial lease contracts end early
In case the financial lease contract ends before the deadline, the leasing organization needs to prepare the following invoices:
Property recovery: The invoice must clearly show the amount of VAT paid, the tax rate is stated as "CTTC", the remaining value without tax is determined according to the property recovery record.
Selling recovered assets: A complete VAT invoice must be issued when transferring recovered assets to the buyer.
Are business households involved?
Circular 32/2025 mainly regulates cases related to enterprises and organizations with specific service activities. However, if a business household operates in the above areas (such as corporate taxi transportation, providing meals under large contracts, etc.), it must also apply electronic invoices according to the provisions of Article 91 of the Law on Tax Administration 2019.
The above guidelines are specifically stipulated in Article 6 of Circular 32/2025/TT-BTC and related provisions in Decree 123/2020/ND-CP, Decree 70/2025/ND-CP. The Circular takes effect from June 1, 2025.
