🚨 [NEW UPDATE] OFFICIAL DISPATCH NO.2268/CT-CS (10 April 2026)

👉 VAT REFUND CONDITIONS FOR EXPORTS – DON’T GET IT WRONG!

The Tax Authority has recently issued important guidance on VAT refunds for exported goods in 2026.
This is a key update that exporting enterprises, especially trading and manufacturing companies, should review promptly
to avoid misunderstandings and delays in VAT refund applications.

🔴 1. When is a VAT refund applicable?

Enterprises may be eligible for a VAT refund when they simultaneously meet the following basic conditions:

• 👉 Have exported goods or services
• 👉 Have uncredited input VAT of 300 million VND or more

➡ Once all conditions are satisfied, the enterprise may be entitled to a VAT refund on a monthly or quarterly basis in accordance with prevailing regulations.

🔴 2. Cases Not Eligible for VAT Refund – Common Pitfalls for Many Businesses

❌ In cases where goods are imported and then re-exported
(i.e., a pure trading model, without any manufacturing, processing, or value addition), then:

➡ NOT eligible for VAT refund

📌 Important note:

• This represents a significant tightening in the VAT refund policy for 2026
• Applicable in cases where:
  • Goods are imported from abroad
  • Then re-exported to another country
  • Whether exported directly or through entrusted export arrangements

🔴 3. Cases Still Eligible for VAT Refund (Commonly Misunderstood)

Some enterprises may still be eligible for a VAT refund if the substance of the transaction complies with applicable regulations, for example:

• ✔ Import raw materials → manufacture/production → export
• ✔ Supply goods to non-tariff zones

➡ These cases may still be considered for VAT refunds.

🔴 4. List of Strictly Scrutinized Risk Behaviors

The tax authorities also emphasize several categories of high-risk behaviors when reviewing VAT refund applications:

• 🚫 Trading in invoices
• 🚫 Creating fictitious transactions
• 🚫 Using invalid or illegal invoices
• 🚫 Failure to transmit invoice data in accordance with regulations

➡ These businesses are more likely to be subject to priority scrutiny in VAT refund reviews, and may even be placed under pre-refund inspection.

💥 MBA Audit Perspective

From 2026 onwards, VAT refunds for exported goods will no longer be a simple administrative procedure.

In practice, this process is increasingly similar to a pre-refund inspection,
where tax authorities will thoroughly review the entire transaction chain.

Enterprises should be fully prepared with:

• Export documentation
• Non-cash payment supporting documents
• A consistent and well-aligned documentation trail covering procurement – production – export – invoicing – customs declarations

➡ Even a single weak link may lead to:

• Suspension of VAT refund applications
• Escalation to tax inspection
• Prolonged processing timelines

📌 Key takeaway

👉 Not all exports qualify for VAT refunds.

👉 Pure trading = NO VAT REFUND.

💬 Which export model is your business currently operating under
manufacturing or trading?
Comment below and MBA Audit will support you with a quick analysis of your VAT refund risks and eligibility.

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