INVOICES FOR GOODS GIVEN, DONATED, PRESENTED AND PROMOTIONAL GOODS FROM JULY 1, 2026

Updated in accordance with Decree No. 254/2026/ND-CP – effective from July 1, 2026

From July 1, 2026, regulations on e-invoices continue to introduce important requirements for goods and services used for promotional activities, advertising, samples, giving, donating, presenting, exchange, payment of employee salaries in kind, and internal consumption.

Notably, Decree No. 254/2026/ND-CP allows enterprises to issue consolidated invoices on a monthly or quarterly basis for promotional goods and services and goods and services given, donated or presented, provided that the applicable conditions are satisfied. This provision can significantly reduce the administrative burden for enterprises with a large number of such transactions.

1. Invoices are still required for goods given, donated, presented and promotional goods

Under Clause 1, Article 4 of Decree No. 254/2026/ND-CP, when selling goods or providing services, the seller is required to issue an e-invoice to the buyer. This requirement also applies to goods and services:

• Used for promotion, advertising or as samples;
• Given, donated or presented;
• Exchanged;
• Used as payment of salaries to employees;
• Used for internal consumption;
• Delivered in the form of loans or lending.

Therefore, the fact that goods or services are provided free of charge does not mean that the enterprise is exempt from issuing an invoice.

Is an invoice still required if the customer does not request one?

Yes. The fact that a buyer or customer does not request an invoice does not eliminate the seller's obligation to issue an invoice if the transaction falls within a case subject to invoicing requirements.

Similarly, for goods and services given to employees, used as payment of salaries, or used for internal consumption, the enterprise must still determine and comply with the invoicing requirements under Decree No. 254/2026/ND-CP.

2. Consolidated invoices may be issued for promotional goods and goods given, donated or presented

One of the notable changes under the new regulations is that enterprises may issue consolidated invoices for:

• Goods and services provided as promotions in accordance with commercial regulations;
• Goods and services given, donated or presented in accordance with applicable laws.

A consolidated invoice may cover transactions arising during a month or quarter, corresponding to the VAT filing period of the organization or individual selling the goods.

This provision is particularly useful for enterprises that regularly conduct gift-giving programs, provide samples or run promotional campaigns involving a large number of customers during a tax period.

Legal basis: Point a.3, Clause 5 of the Appendix on “Invoice Contents” issued together with Decree No. 254/2026/ND-CP.

Note where the customer requests a separate invoice

The ability to issue a consolidated invoice does not mean that an enterprise may always refuse to issue a separate invoice.

If the customer requests an invoice for each individual transaction, the seller must issue the invoice to the customer in accordance with the regulations.

Therefore, enterprises should establish an internal process to determine:

1. Which transactions may be included in a consolidated invoice;
2. The period for issuing the consolidated invoice;
3. How detailed transaction records should be maintained;
4. How to handle cases where customers request separate invoices.

3. Consolidated invoices must be accompanied by a detailed statement

For a consolidated invoice, the invoice must clearly state “Attached to Statement No. ..., dated .../.../...”

The statement must contain the information required by law, including:

• Seller's name, tax identification number and address;
• Name of goods or services;
• Quantity;
• Unit price;
• Amount of goods or services sold;
• Date of preparation of the statement;
• Name and signature of the person preparing the statement.

Where the seller declares VAT under the credit-invoice method, the statement must also include:

• VAT rate;
• VAT amount.

The total payment amount stated in the statement must correspond to the amount stated on the VAT invoice.

In addition, goods and services listed in the statement must be arranged in the order in which the sales occurred during the day, and the statement must clearly state “Attached to Invoice No. ... dated .../.../...”

Where goods and services are listed in an attached statement, the unit price is not necessarily required to be shown on the invoice.

Legal basis: Points a.3 and a.4, Clause 5 of the Appendix on “Invoice Contents” issued together with Decree No. 254/2026/ND-CP.

Enterprises should maintain statements containing sufficient information, including:

Transaction date → Recipient → Goods/services → Quantity → Unit price → Amount → VAT rate → VAT amount → Related supporting documents.

This enables the amounts on the consolidated invoice to be readily reconciled with accounting records, inventory records and promotional documentation.

4. Enterprises must retain detailed lists and supporting documents

The issuance of a consolidated invoice does not reduce the enterprise's responsibility for retaining supporting documents.

Enterprises should:

• Retain a detailed list of promotional goods and services and goods and services given, donated or presented;
• Retain relevant documents and records relating to the transactions;
• Ensure that the consolidated invoice fully and accurately reflects the transactions arising during the relevant period;
• Provide information and supporting documents for tax administration purposes when requested by the competent authorities.

What documents should enterprises retain?

Depending on the specific program, enterprises should retain at least:

• Promotional decision/program;
• Promotional registration or notification documents, where required;
• List of customers/recipients;
• Warehouse release notes or delivery/receipt documents;
• Detailed statement of goods and services;
• Consolidated e-invoice;
• Other documents supporting the giving, donation, presentation or promotion of goods and services.

Maintaining complete documentation enables the enterprise to demonstrate the validity of the transactions and facilitate reconciliation during a tax inspection.

5. VAT taxable price for goods given, donated or presented

For goods and services given, donated or presented, the VAT taxable price is determined based on the price of goods or services of the same type or equivalent at the time the giving, donation or presentation takes place.

Accordingly, although the enterprise does not receive payment from the recipient, the transaction may still give rise to VAT obligations based on the applicable taxable price.

Legal basis: Current VAT regulations governing the taxable price of goods and services used for giving, donation or presentation. Law No. 48/2024/QH15 on VAT took effect on July 1, 2025 and is further guided by Decree No. 181/2025/ND-CP, as amended and supplemented by Decree No. 144/2026/ND-CP.

6. VAT taxable price for promotional goods and services

For goods and services provided as promotions in compliance with commercial regulations, the taxable price of the promotional goods and services may be determined as VND 0 in accordance with the applicable regulations.

However, where an enterprise gives goods away but the transaction does not satisfy the legal requirements for a promotional activity, the transaction may instead be treated in accordance with the regulations applicable to goods and services given, donated or presented.

Therefore, enterprises should distinguish between:

Incorrect classification may result in an incorrect determination of the VAT taxable price.