Vietnam new VAT law: what changed from July 2025

Vietnam new VAT law means Law 48/2024/QH15, which the National Assembly passed on 26 November 2024. It replaced the 2008 VAT law on 1 July 2025. It changed how firms claim input VAT, how they get refunds, and who pays VAT at all. It has also been amended twice since, so the rules today differ a little from the first text.

When the law started and what it replaced

The law has 4 chapters and 18 articles. Most of it took effect on 1 July 2025. It ended the 2008 VAT law and the amendments made to that law in 2013, 2014 and 2016. A few parts, such as the rule for small household businesses, were set to start on 1 January 2026.

The law is a framework. The government then issued Decree 181/2025/ND-CP on 1 July 2025 to explain several provisions. Law 90/2025/QH15, passed in June 2025, also changed parts of the VAT law, including the treatment of goods delivered inside Vietnam on the order of a foreign buyer.

Sources: Deloitte Vietnam tax alert on Law 48/2024/QH15 (December 2024); Forvis Mazars Vietnam newsletter on the new VAT law; Vietnam Briefing, "Vietnam's New VAT Law: Key Compliance Guidance"; EY Vietnam tax alert, December 2025.

Invoice and input VAT rules

The new law ties the right to deduct input VAT to proof of payment. Before, the minimum invoice value for a non-cash payment voucher sat in the law, and the new law dropped it. Decree 181/2025/ND-CP, which guides the law, now says a non-cash payment voucher is needed for goods and services of VND 5 million or more, VAT included. Imported goods are covered too.

Firms that export need more papers to deduct input VAT. These include a packing list, bills of lading and insurance documents where they exist.

The law also sets the time when VAT is due, and it puts this rule in the law itself. For goods, it is when ownership or the right to use passes to the buyer, or when the invoice is issued, whichever applies. For services, it is when the service is finished or the invoice is issued. Payment does not have to be received first.

If a firm finds an error in its input VAT, it must file a corrected return before the tax office announces an audit or inspection. Where is the fix booked? That depends on the case. If the fix raises tax due or cuts a refund, it goes into the period of the error. If it cuts tax due, it goes into the period when the error was found.

The law also lists banned acts. They include buying and selling invoices, using illegal invoices, creating fake deals, and failing to send e-invoice data as required.

Sources: Deloitte Vietnam tax alert on Law 48/2024/QH15 (December 2024); Vietnam Briefing, "Vietnam's New VAT Law: Key Compliance Guidance" (December 2025).

Refund rules

The law widened some refunds and closed others. A firm that sells only goods or services taxed at 5 percent, and has at least VND 300 million of input VAT not yet offset after 12 months or 4 quarters, can ask for a refund. Firms with mixed rates get a refund by an allocation rate set by the government.

For investment projects, expansion projects can now qualify. A firm has one year to file the refund file after the project, or a stage of it, is complete. The completion date is the day the project first earns revenue, not counting trial runs, financial income or the sale of scrap raw materials.

For exporters, goods that were imported and then sent abroad do not qualify for a refund. The law also explains how to split input VAT between exports and local sales.

Refunds because of a sale of a business, a change of company type, a merger or a split were removed. Refunds on dissolution or bankruptcy stay.

The first text also said the seller must have declared and paid the VAT on the invoices a buyer used to claim a refund. Businesses said this was a heavy burden. In December 2025 the National Assembly passed Law 149/2025/QH15, which dropped that condition from 1 January 2026.

Sources: Deloitte Vietnam tax alert on Law 48/2024/QH15 (December 2024); EY Vietnam tax alert on Law 149/2025/QH15 (December 2025).

Small firms and household businesses

The law raised the line below which household and individual businesses owe no VAT. Vietnam Briefing reports the old line was VND 100 million of yearly revenue. The 2024 law set it at VND 200 million from 1 January 2026. Law 149/2025/QH15 then lifted it to VND 500 million from the same date. That matches the personal income tax exemption line. EY also notes the "deemed tax" method for these taxpayers was dropped.

This is the biggest change for small shops and sole traders. A business with yearly revenue up to the line does not need to charge VAT.

Sources: Deloitte Vietnam tax alert (December 2024); EY Vietnam tax alert (December 2025); Vietnam Briefing.

Digital sellers, rates and farm goods

Foreign suppliers with no permanent establishment in Vietnam that sell through e-commerce or digital platforms to Vietnamese buyers are now covered, and a 10 percent rate applies to their services. Platforms with payment functions must withhold and pay tax for household and individual sellers on them.

The law also moved some goods between rate bands. Fertilizer and some farm machines moved to 5 percent. Some services, such as securities services, moved to 10 percent. Fresh food sold by those who grow or catch it stays outside VAT.

Raw farm goods changed twice. The 2024 law made the sale between firms taxable at 5 percent with credit rules. Law 149/2025/QH15 returned sales between firms to "not subject to VAT declaration and payment" from 1 January 2026. Processed farm goods stay at 10 percent.

Law 90/2025/QH15 added a clear rule for on-the-spot export and import. Goods delivered and received in Vietnam as a foreign trader directs, under a sale, processing, lease or loan contract, can now use the 0 percent export rate.

Sources: Deloitte Vietnam tax alert (December 2024); EY Vietnam tax alert (December 2025); Vietnam Briefing.

What firms should check now

Start with payment proof. Check that each purchase of VND 5 million or more that you deduct has a non-cash payment voucher. Keep export papers together.

Next, review refund files. If you sought a refund in 2025, check whether the seller condition still affects your file, since it was dropped from 1 January 2026. Household businesses should compare yearly revenue with the new line.

Finally, read the decrees and circulars. Deloitte noted that the law sets principles and that details come through guidance documents. For any single case, ask a licensed tax adviser.

Sources: Deloitte Vietnam tax alert (December 2024); EY Vietnam tax alert (December 2025).