Summary of Key Updates in Circular No. 32/2025/TT-BTC on Invoices and Documents

On May 15, 2025, the Ministry of Finance issued Circular No. 32/2025/TT-BTC providing detailed regulations and guidance on the implementation of several articles of Decree No. 123/2020/ND-CP (as amended and supplemented by Decree No. 70/2025/ND-CP) relating to electronic invoices and documents. This Circular takes effect on June 1, 2025 and includes many important amendments and additions.

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1. Amendment of Regulations on Authorization for Issuing E-Invoices

● Elimination of the "affiliated relationship" requirement between parties to the authorization

(Point a, Clause 1, Article 4 of Circular 32/2025/TT-BTC)

According to Decree 32/2025, the Ministry of Finance has eliminated the requirement that the seller of goods or services must be an "enterprise, economic organization, or other organization", and also removed the requirement for an "affiliated relationship" between the authorizing party and the authorized party.

→ Instead, a general condition applies: The authorized party must meet the requirements for using e-invoices and must not fall under the cases of suspended use as per Article 16 of Decree No. 123/2020/ND-CP (amended by Clause 12 Article 1 of Decree No. 70/2025/ND-CP).

→ This regulation broadens the scope of entities eligible to be authorized, enhancing flexibility for sellers in selecting partners to issue e-invoices.

● Additional requirements for the contents of the authorization agreement

(Clause 2, Article 4 of Circular 32/2025/TT-BTC)

The authorization agreement/contract must include:

• Information: Name, address, tax code/personal identification number, and digital certificate of both parties;

• Details of the authorized e-invoice: type, symbol, form number, purpose, duration, payment method, and payment responsibility;

• Obligation to retain and present the document when required by competent authorities.

→ Compared to Circular 78/2021/TT-BTC, the new regulation specifies the required contents of the agreement, enhancing transparency, authenticity, and security in electronic transactions.

● Additional responsibilities for e-commerce platforms when receiving authorization

(Point c, Clause 3, Article 4 of Circular 32/2025/TT-BTC)

If a business household or individual authorizes an e-commerce platform to issue e-invoices, the platform must notify the tax authority on behalf of the seller.

→ Circular 78/2021 did not address this. The new provision reflects the actual development of e-commerce, ensuring tax compliance and supporting small business households/individuals.

● E-invoices issued by authorized parties must align with the tax method of the authorizing party

(Point h, Clause 1, Article 4 of Circular 32/2025/TT-BTC)

E-invoices issued by the authorized party must correspond to the tax method (declaration or presumptive) of the authorizing party.

→ This ensures consistency in tax and invoicing, reducing errors in tax declarations.

Circular No. 32/2025/TT-BTC

2. Additional regulations on invoice form symbols and invoice codes

(Clause 1, Article 5 of Circular 32/2025/TT-BTC)

● Invoice form symbols:

• Code 7: E-commerce invoice

• Code 8: VAT invoice integrated with tax/fee/charge receipts

• Code 9: Sales invoice integrated with tax/fee/charge receipts

● Invoice codes:

• Letter "X": Applied to e-commerce invoices→ Example: 7K25XAB = E-commerce invoice issued in 2025

3. Guidance on implementation of personal income tax (PIT) withholding documents under Decree 70/2025/ND-CP

From June 1, 2025, PIT withholding organizations must stop using previously applied PIT electronic withholding documents and switch to new formats under Decree 70.

→ If previous documents were issued incorrectly, new e-withholding documents must be issued as replacements.

4. Supplementation of special cases for using e-invoices

● Financial leasing activities

(Clause 2, Article 6 of Circular 32/2025/TT-BTC)

• Mandatory issuance of VAT invoices for leasing assets;

• VAT input invoice (or import tax document) is required;

• Output VAT must match input VAT;

• Use the “CTTC” tax rate symbol on the invoice;

• If there’s no input invoice, VAT must not be stated;

• When selling repossessed assets, issue a VAT invoice indicating VAT amount per the asset recovery record.

● Sales and services with large quantity and regular occurrence

(Clause 1, Article 6 of Circular 32/2025/TT-BTC)

Allowed to issue invoices after data reconciliation, not at the time of delivery. Applicable for:

• Derivative products;

• Industrial catering services;

• Commodity exchanges;

• Credit information services;

• Passenger transport by taxi (for corporate clients).

5. Guidance on users of e-invoices generated from cash registers

(Clause 5, Article 12 of Circular 32/2025/TT-BTC)

Enterprises selling directly to consumers that have registered with tax authorities but have not yet complied with the standard data format, must register to use e-invoices generated from cash registers.

Note: Once switched to this invoice type and accepted by the tax authority, enterprises may not revert to using coded/non-coded e-invoices used previously.

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