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According to a representative of the competent authorities, a common scheme used by individuals who illegally buy and sell invoices is to “cut the traces of money flow through banks” by withdrawing cash and then depositing it into personal accounts to carry out off-book transactions.
The new provisions of the VAT Law 2024 clarify eight cases eligible for VAT refunds. The law also adds and removes certain provisions to ensure consistency with the essence of the tax and management requirements in the new context.
Key changes include:
From a practical law enforcement perspective, representatives of the Police said that tightening VAT refund policies will help curb invoice turnover fraud, the creation of fake export documents, and the formation of fake transaction chains designed to misappropriate refund monies.
Local authorities in Hai Phong noted that although there have been positive results, the refund process remains risky. Fraudulent acts are increasingly organized, with links across many enterprises and even across jurisdictions.
According to the Police, while money transfers via banks may match the invoice value, the underlying goods or services are not real. As a result, the buyer’s payment to the seller is effectively only the tax and fees stated on the invoice.
The Police described the common tactic as withdrawing cash and then depositing it into personal accounts to transact off the books, even when bank transfers appear to align with invoice amounts.
The Police said that lowering the threshold for required banking payments from 20 million VND to 5 million VND—and moving toward even lower thresholds—will force more banking transactions for illegal invoices. With cooperation between commercial banks and authorities, the money trail can be traced to uncover and clarify invoice fraud aimed at obtaining tax refunds, including VAT refunds.
Thượng tá Trần Quang Tuấn emphasized that authorities will accompany legitimate businesses, but will strictly handle acts of profiteering and misappropriation of state funds, with the motto “no area is off-limits, no exceptions.”

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