Beyond sales invoices: e-documents for PIT withholding, internal stock transfers and branches in Vietnam

Vietnam's invoicing framework covers more than the invoice a company sends to a customer. The same rules deal with electronic documents such as personal income tax (PIT) withholding certificates, with notes that accompany goods moved between a company's own sites, and with invoices for goods that leave the company without a sale — samples, promotional items, gifts. A foreign-invested enterprise (FIE) whose e-invoice project covered only customer invoices has usually left these three areas to chance.

None of them is complicated once identified. The problem is that each one belongs to a different team — HR and payroll, logistics, marketing — and none of those teams thinks of itself as issuing tax documents. This guide takes the three areas in turn and says what to put in place.

One framework, several kinds of document

The rules are in Decree 123/2020/ND-CP on invoices and documents, as amended by Decree 70/2025/ND-CP, with guidance in Circular 78/2021/TT-BTC. Since 1 July 2026, Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC on e-invoices and electronic documents also apply. We do not summarise the 2026 texts; their titles alone show that electronic documents are treated alongside invoices, and any procedure covered here should be checked against them.

PIT withholding certificates for employees and contractors

An employer that withholds PIT from payments to an individual issues a withholding certificate showing the income paid and the tax withheld. Under the current framework these certificates can be issued electronically, through the same kind of service used for e-invoices, and signed with the company's digital signature.

They matter most in three situations:

• Casual workers and short contracts. A company paying an individual without a labour contract, or under a contract of less than three months, withholds 10% on payments of VND 2 million or more per payment, unless the individual has given a valid commitment under the current circular. The individual needs the certificate to finalise or claim a refund.
• Employees who finalise their own tax. Someone who changed employers during the year, or has other income, needs certificates from each payer to prepare their own finalisation.
• Expatriates leaving Vietnam. An assignee going home usually needs evidence of Vietnamese tax paid to claim credit in the home country. The certificate, together with the finalisation, is that evidence. Producing it after the person has left, from a payroll that has already been closed, is much harder than producing it before departure.

Put the certificate process with payroll, not with the tax team, and include it in the leaver checklist for every expatriate. Since 1 July 2025 an individual's personal identification number is used in place of a personal tax code, so check that payroll records carry the right identifier for Vietnamese staff.

Moving stock between your own sites

Many FIEs have more than one physical site: a factory and a separate warehouse, a head office and a branch in another province, a bonded area and a domestic area. Goods moving between them are not sold, but they still travel on public roads and cross from one set of books to another.

The invoicing rules provide for documents that accompany such movements — in Vietnamese practice, the phiếu xuất kho kiêm vận chuyển nội bộ, an internal delivery note used and managed like an invoice. The questions to settle with an adviser:

1. Which movements need the internal note, and which need an invoice. A transfer of goods to a branch that will sell them may be treated differently from a transfer of materials for further production. The answer depends on how the branch is registered and how it declares tax.
2. How the note is issued. If it is issued electronically, the same registration, signature and provider arrangements apply as for sales invoices.
3. How stock records follow. The quantity on the note should match the warehouse issue at the sending site and the receipt at the receiving site, on dates that make sense.

Companies with an export processing or bonded status have an extra layer: movements between the bonded area and the domestic market are also governed by customs procedures, and the tax treatment of goods crossing that line differs from an ordinary domestic transfer. Treat any such movement as a customs question first and an invoicing question second, and do not let a warehouse team use the same internal note for both kinds of movement simply because the trucks look the same.

A related document covers goods sent to agents to sell on the company's behalf. If your distribution model uses consignment or agents rather than outright sales, confirm which document applies before the first delivery.

Branches with their own tax codes

A dependent branch in another province often has its own tax code and may be required to declare certain taxes locally. That changes who issues what:

• Sales made by the branch are usually invoiced in the branch's name and tax code, through its own registration, if it is set up to do so.
• Goods and services the head office provides to the branch, or the branch to the head office, need a documented treatment — internal note, invoice or allocation — agreed in advance and applied consistently.
• The branch's managing tax office may be a different grassroots tax office (Thuế cơ sở) from the head office's, and it sees only the branch's data.

The most common failure is a group ERP that treats the branch as a cost centre of the head office. That works for management accounts and fails for tax, because the tax authority treats a branch with its own tax code as a separate declarant. Map the branch as its own company code, or at least as its own tax reporting unit, in the ERP.

Samples, promotional goods and internal use

Goods that leave the company without a sale still leave. The invoicing rules generally require an invoice when goods are used for promotion, advertising or samples, given as gifts, exchanged, used to pay employees, or consumed internally other than to continue production. The invoice shows the goods and their value as the rules prescribe; how VAT applies depends on the kind of use and on whether a registered promotional programme is involved.

For a consumer-goods FIE, that means the marketing calendar is also an invoicing calendar. A product launch with thousands of samples, a year-end gift to distributors, a staff allowance paid in products — each needs a decision on documentation before the goods leave the warehouse. Record the business purpose and the recipients alongside the invoice. An inspector reviewing a large stock write-down labelled "marketing" will ask what happened to the goods, and "we gave them away" needs paper behind it.

Do not treat this as a way to shift value. Goods recorded as samples that were in fact sold, or gifts that were in fact commissions to a customer's staff, are a problem no document fixes.

Putting it together, and where to check

Ask three owners three questions:

• Payroll: Can we issue an electronic withholding certificate for any person paid this year, including leavers, within a week of being asked?
• Logistics: For each type of movement between our sites, which document travels with the goods, and who issues it?
• Marketing: For each programme that gives goods away this year, who has confirmed how it will be invoiced?

Check the position through the tax authority's e-invoice portal (invoices and internal notes issued by each registered unit), the taxpayer information lookup (status and managing tax office of each branch) and the company's e-tax account (returns and payments per unit). All of these documents are accounting records; keep them for at least 10 years under the Law on Accounting. Payments to overseas group companies are a separate topic, covered under foreign contractor tax.