VAT REFUND TOPIC · GUIDANCE FOR ENTERPRISES
🚢 VAT REFUND FOR EXPORTS: DETERMINING THE REFUNDABLE AMOUNT AND PREPARING THE DOSSIER
Exporting enterprises may maintain steady sales and collect payments on time, yet still accumulate a substantial amount of input VAT.
When planning working capital, the key question is not merely “how much input VAT remains deductible”, but rather “how much of that amount is eligible for a refund, and what documentation is required to substantiate it?”
The 0% output VAT rate, the right to input VAT deduction, and VAT refund conditions are matters that should be examined separately.
The entire input VAT balance recorded in the accounting books should not be treated as the expected refundable amount.
📑 Key Contents
📌 1. Identify the correct export activities before calculating the refund
Clause 1, Article 15 of the Law on Value-Added Tax stipulates a VND 300 million threshold for refund consideration and limits the refund amount to no more than 10% of export revenue for the refund period. For enterprises with both domestic and export revenue, the input VAT attributable to exports must be determined and offset in accordance with regulations.
[1]
First, revenue should be divided into separate groups: goods actually exported overseas; services provided to foreign customers; deliveries within Vietnam as instructed; transactions with export processing enterprises; and goods imported and then exported. This grouping helps identify transactions requiring further review, rather than assuming that all transactions are eligible for a refund.
⚠️ Exclusion note:
Imported goods that are subsequently exported to another country are not eligible for a refund under this category. This regulation distinguishes them from imported raw materials used for the production or processing of goods for export.
[2]
🧮 2. Calculate the refund claim amount in the correct order
1️⃣ Determine the refund period
Prepare a schedule showing the continuous movement of uncredited input VAT and check the periods for which refunds have already been processed.
2️⃣ Filter eligible inputs
Identify items requiring additional documentation or items that do not meet the eligibility conditions before allocation.
3️⃣ Separate export-related inputs
Priority should be given to separate accounting; any portion that cannot be separately accounted for should be allocated in accordance with regulations.
4️⃣ Offset
Determine the remaining amount after offsetting against tax obligations arising from domestic activities.
5️⃣ Check thresholds and ceilings
Check the VND 300 million threshold and the limit of 10% of export revenue for the refund period.
📌 Provisions on refund periods, allocation, offsetting and limits: Article 29 of Decree No. 181/2025/ND-CP in the consolidated text.
[2]
The revenue ratio of the final month alone should not be used if the refund period spans multiple periods; nor should amounts directly attributable to exports be reallocated.
📊 3. Example where both export revenue and domestic revenue exist
Assume that the enterprise has no non-taxable revenue and no special circumstances. All figures below relate to the same refund period, have not been refunded previously, and meet the documentation requirements. Unit: VND billion.
| Item | Data | Determination method |
|---|---|---|
| Export revenue | 20 | Eligible revenue used for the refund calculation. |
| Taxable domestic revenue | 10 | Total taxable revenue is 30. |
| Input VAT separately accounted for exports | 1.8 | Do not reallocate. |
| Shared input VAT requiring allocation | 1.2 | Portion attributable to exports: 1.2 × 20/30 = 0.8. |
| Total export-related input VAT | 2.6 | 1.8 + 0.8. |
| Domestic tax payable requiring offsetting | 0.4 | Assumed to have been calculated after deducting domestic input VAT. |
| Remaining export-related input VAT | 2.2 | 2.6 – 0.4; reaches the VND 300 million threshold. |
| Limit of 10% of export revenue | 2.0 | 20 × 10%. |
| 💰 Maximum refundable amount to be considered | 2.0 | Take the lower of the two amounts: 2.2 and 2.0. |
🧮 ILLUSTRATIVE RESULT
Maximum refundable amount to be considered: VND 2.0 billion
The excess amount of VND 0.2 billion should continue to be tracked for deduction and refund determination in subsequent periods in accordance with regulations. This example illustrates the calculation logic; it does not replace the actual calculation process, which may involve revenue adjustments, multiple types of activities or complex carry-forward figures.
📂 4. Organize documents by transaction
A common reference code should be assigned to the contract, order, invoice, delivery, customs and payment records. Organizing data by transaction helps explain discrepancies between documents, rather than simply grouping each type of document into separate, disconnected folders.
| Review area | Working documents to be compiled | Questions to be answered |
|---|---|---|
| 📄 Sales agreement | Contracts, addenda and purchase orders. | Who is the buyer and who is the recipient? What are the price and delivery terms? |
| 🧾 Invoices and declarations | Invoices, adjustments/replacements (if any), and revenue schedules. | Have the transaction and period been recorded correctly? |
| 🚚 Flow of goods | Customs, transport, packaging and delivery documents appropriate to each transaction. | Can the quantity, description of goods, delivery location and delivery date be explained? |
| 🏦 Cash flow | Credit advices, bank statements, offsetting schedules or third-party documentation, if applicable. | Which invoice does this payment relate to? Why does the actual amount received differ from the contract value? |
| 📦 Inputs | Purchase invoices, payments, warehousing records, production records and cost allocation schedules. | Which orders, product groups or activities do the costs serve? |
⚠️ Note
This is a proposed working checklist. Required documents and exceptions must be determined based on the type of export; the full customs dossier for goods should not be mechanically applied to service exports.
🗂️ 5. Submission dossier and four implementation steps
Pursuant to Point a, Clause 1, Article 46 of Circular No. 89/2026/TT-BTC, the export VAT refund dossier uses Form 01/GTGT (containing the refund request field) and Appendix 01-8/GTGT.
[3]
For dossiers relating to earlier periods, transitional provisions should be reviewed before applying the forms.
1️⃣ Finalize the dataset
The Accounting, Import-Export and Sales departments agree on the list of transactions included in the refund period.
2️⃣ Check the amount
Prepare a schedule of allocation, offsetting and limits, together with a list of items not yet included.
3️⃣ Submit and monitor
Submit the dossier to the correct receiving authority, retain the electronic notification and assign a focal point.
4️⃣ Provide explanations and receive results
Respond to each issue, update the accepted figures and retain the final set of documents.
⚠️ 6. Three situations where conclusions should not be drawn too quickly
🏦 Customer payment shortfall due to bank charges
Before treating the situation as a payment shortfall, it is necessary to determine the party responsible for the bank charges based on the contract, bank documents and the relevant accounting treatment.
A discrepancy requiring explanation does not, in itself, prove whether the transaction satisfies the conditions.
📍 Sale to a foreign party but delivery in Vietnam
The nature of the transaction, on-the-spot import/export procedures, relevant documentation and the timing of policy application should be examined separately. The customer’s nationality alone is not sufficient to draw a conclusion.
📈 Inputs are significantly higher than revenue for the current period
Inventory levels, production cycles, carry-forward amounts and refund limits should be reviewed. An increase in input VAT should not be used as the sole basis for projecting a corresponding increase in VAT refunds.
💰 7. How should VAT refunds be incorporated into the cash flow plan?
Three separate columns should be set up: the tax amount currently being tracked, the amount with a basis for refund claim, and the amount for which a refund decision has already been issued. Each item should have an update date and a person in charge. For dossiers currently under explanation or review, a slower-than-expected cash flow scenario should be prepared to avoid relying on an uncertain receipt date.
💡 Pre-submission question:
Can someone who did not personally prepare the file read the spreadsheet and trace each figure back to its supporting documents?
If not, the business should first finalize its data-linking method.
💬 Discuss your needs with MBA
MBA Auditing Firm Co., Ltd. assists in reviewing conditions, data and VAT refund documentation, and coordinates the provision of explanations within the agreed scope of work.
Enterprises may submit preliminary information on the type of export, expected refund period, export revenue, remaining creditable tax amount and key issues. Please use the subject “Review of refundable export VAT” when contacting us to discuss the scope of assistance.
🌐 Official contact information: mba-au.com.
The scope, timeline and service fees are determined following an initial assessment. The final outcome falls under the authority of the tax authority.
📖 Legal Basis and References
- Clause 1, Article 15 of the current Law on Value-Added Tax – consolidated text, Official Gazette.
- Article 29 of Decree No. 181/2025/ND-CP in the consolidated text published in the Official Gazette.
- Point a, Clause 1, Article 46 of Circular No. 89/2026/TT-BTC – legal document reference.
For dossiers spanning multiple periods, transitional provisions and the legal documents applicable at the time the relevant events occurred or the dossiers were submitted should be reviewed. The task lists, examples and file organization methods presented in this article are practical suggestions only; they are not mandatory templates or formal advisory conclusions for any specific business.
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