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The Vietnam Chamber of Commerce and Industry (VCCI) has proposed adjustments to several provisions in the draft Circular on electronic invoicing and electronic documents, with a focus on rules applicable to electronic commerce.
One key proposal relates to how electronic invoices should be adjusted when errors occur during online transactions.
Under current regulations, the invoicing time for the sale of goods (including the sale and transfer of state-owned assets or national reserves) is determined by the time of ownership or the right to use the goods to the buyer, regardless of whether payment has been completed.
For exports (including outsourced export), the timing for issuing electronic commercial invoices, electronic VAT invoices, or electronic sales invoices is determined by the seller but must be no later than the next business day after the goods are cleared for customs.
VCCI argues that e-commerce differs from traditional trading because there is often a gap between delivery and transaction completion. During this period, buyers may return goods—typically lasting from 7 to 15 days depending on platform policy—leading to relatively frequent needs to adjust or cancel electronic invoices.
VCCI said the draft does not fully reflect these characteristics because it is still based on traditional transaction models. As a result, enterprises and individual traders may face higher costs and additional administrative procedures when handling returns or changes to transaction content.
VCCI proposes two directions to better align the rules with e-commerce practice:
VCCI also commented on the regulation regarding authorization to issue electronic invoices in e-commerce. Clause 3 of Article 5 of the Draft states that if a household or individual business authorizes an organization managing the e-commerce platform to issue invoices, the organization must notify the tax authority.
VCCI noted that such authorization is considered a change in electronic invoicing registration information and therefore must follow notification procedures.
According to VCCI, while this approach may be suitable for isolated cases, applying it to platforms with many sellers and continuously changing delegated authorizations would create significant administrative burden.
VCCI said that most online transactions and platform agreements are conducted online, with data stored comprehensively and transparently and available for verification when needed. Based on this practice, VCCI proposed that the drafting agency adjust the approach to allow e-commerce platforms to consolidate authorization-related changes and submit periodic reports monthly or quarterly, instead of notifying each case individually.
VCCI said the proposed solution would balance transparency in platform management with reducing administrative costs and burdens for both businesses and the tax authority.
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