Uni 21-04-2026 - Invoice exchange rate

Official letter 2344/CT-CS about invoice exchange rate:

Based on the above regulations and the presentation of the Can Tho City Tax Department in công văn (official letter) No. 4889/CTH-QLDN3, the time of issuing an invoice for the sale of goods is the time of transferring ownership or the right to use the goods to the buyer, regardless of whether payment has been received or not. In cases where economic and financial transactions arise in foreign currency as stipulated by the law on foreign exchange, the Tax Department agrees with the proposal of the Can Tho City Tax Department to implement Option 1.

Upon review, there are currently two viewpoints (two options) as follows:

• Option 1: Use a single exchange rate, which is the actual transaction rate at the time of invoice issuance.
• Option 2: Use two exchange rates on the same invoice (separating the advance payment and the remaining amount).

Can Tho City Tax Department proposes implementing Option 1, for the following reasons:

• Time of tax determination and invoice issuance: The advance payment is only a deposit or guarantee for contract performance. At the time of receiving the advance payment, ownership of the goods has not yet been transferred, therefore the time of VAT determination does not arise. The sales transaction is only truly completed and tax obligations arise at the time of goods handover/invoice issuance.
• Consistency of invoices: Electronic invoices are documents that determine tax obligations at a specific point in time. Displaying two different exchange rates on the same invoice for the same type of goods (in the same foreign currency) is inconsistent with the current electronic invoice data structure (current software only supports entering one exchange rate per invoice) and creates difficulties for tax declaration and management.
• Distinguishing between Accounting and Taxation: The regulation in the Ministry of Finance Circular regarding revenue recognition based on the exchange rate at the time of advance payment serves the purpose of accounting record keeping. However, for VAT invoice preparation and tax declaration, consistency must be maintained according to the time the tax obligation arises (the time of handover). Any difference (if any) between the exchange rate on the invoice and the exchange rate recorded in the accounting books will be accounted for as financial revenue/expenses as prescribed.

The Can Tho City Tax Department respectfully submits this to the Tax Department for consideration and guidance so that the Can Tho City Tax Department has a basis to guide the unit in implementation./