🧾 1. When may an invoice be denominated in a foreign currency?

For economic and financial transactions arising in a foreign currency in accordance with foreign exchange regulations,
the seller shall present the monetary amounts on the invoice in accordance with the regulations on e-invoices.

At the same time, the invoice must show the applicable exchange rate between the foreign currency and Vietnamese
Dong in accordance with regulations.

📌 2. Which exchange rate should be shown on the invoice?

According to Official Letter No. 6810/CT-QLNT:

This is an important point because, in practice, enterprises may encounter several different exchange rate
concepts at the same time:

• 💱 Actual transaction exchange rate for accounting purposes;
• 🧾 Exchange rate used for invoicing;
• 💰 Exchange rate used for tax declaration and payment;
• 🚢 Exchange rate used for tax calculation on exported and imported goods;
• 🏦 Actual exchange rate applied when payment is made through a bank.

📊 3. How is the “actual transaction exchange rate” determined
for accounting purposes?

Under the current enterprise accounting regulations, transactions denominated in foreign currencies must be
translated using an exchange rate appropriate to the nature and substance of the underlying economic transaction.

The actual transaction exchange rate on the transaction date may be determined based on:

• 🏦 The average telegraphic transfer buying and selling exchange rate quoted by the commercial bank with
  which the enterprise regularly conducts transactions; or
• 📌 An approximate exchange rate that satisfies the conditions prescribed under accounting regulations.

💰 4. Must the exchange rate shown on the invoice always be the
same as the exchange rate used for tax declaration and payment?

It should not be assumed that they are always the same.

Official Letter No. 6810/CT-QLNT distinguishes between the following:

🚢 5. What if the enterprise is engaged in import-export activities?

For exported and imported goods, the exchange rate used for tax calculation shall be determined in accordance
with customs regulations.

Therefore, an import-export transaction may involve several exchange rates at the same time:

• 🧾 Exchange rate shown on the invoice;
• 📊 Exchange rate used for accounting purposes;
• 🚢 Customs exchange rate used for tax calculation;
• 🏦 Actual payment exchange rate.

🔎 6. Why can discrepancies arise?

A foreign currency transaction may go through several stages:

If different departments use exchange rates differently without a consistent policy, discrepancies may arise between:

• 🧾 E-invoices;
• 📊 Revenue and receivables/payables recorded in the accounting books;
• 💰 Tax records;
• 🏦 Bank statements and payment documents;
• 🚢 Customs declarations.

⚠️ 7. Common mistakes

Enterprises should pay attention to the following:

• ❌ Automatically using the tax calculation exchange rate or customs exchange rate on the invoice;
• ❌ Failing to determine or retain supporting evidence for the actual transaction exchange rate;
• ❌ Using an exchange rate that is inconsistent with the accounting policy adopted by the enterprise;
• ❌ Failing to distinguish between the accounting exchange rate and the exchange rate used for tax purposes;
• ❌ Failing to reconcile invoices with accounting records, contracts and payment documents;
• ❌ Recording exchange rate differences without correctly identifying the nature of the underlying transaction.

✅ 8. How should enterprises manage foreign currency transactions?

For transactions denominated in foreign currencies, enterprises should follow these steps:

💡 KEY POINT TO REMEMBER

According to the latest guidance from the Tax Department, for economic and financial transactions arising in foreign
currencies:

Meanwhile, exchange rates used for tax declaration, tax payment or tax calculation for imported and exported goods
should be determined in accordance with the relevant regulations applicable to each purpose.

Correctly distinguishing between these exchange rates helps enterprises maintain consistency across:

This makes it easier for enterprises to reconcile records and explain discrepancies when necessary.