VAT refunds in Vietnam: which cases qualify and why claims get delayed

A company in Vietnam can claim a VAT refund only in the cases listed in Law 48/2024/QH15 on Value Added Tax. For foreign-invested companies the two that matter most are exporters whose input VAT exceeds their output VAT, and new investment projects that pay VAT on construction and equipment long before they sell anything. In every other situation, surplus input VAT is simply carried forward to later periods.

A refund is not a formality. The claim is checked against your invoices, your payments, your export documents and, often, your suppliers. Claims that are prepared as if for an audit move faster; claims that assume the tax office will fill gaps do not. This guide covers the cases, the process and the gaps we see most often.

The refund cases in outline

The VAT law and Decree 181/2025/ND-CP set the cases and conditions. In outline:

Each case has conditions — minimum amounts, time periods, exclusions — set out in the law and decree. We do not repeat the figures here because they are precisely the details that change between versions of the rules; read the current decree for the case you intend to use, and check it again before each claim.

The tourist refund is handled by designated retailers and at border gates rather than by the visitor's own filing. Circular 84/2026/TT-BTC governs VAT refunds to foreigners buying goods in Vietnam; retailers joining the scheme should read it directly.

Exporters: where the numbers come from

An exporter builds up uncredited input VAT because its main sales are at 0% while its purchases carry 5% or 10%. The refundable amount is tied to the input VAT attributable to exports, so a company that also sells domestically must separate its inputs — directly where possible, by allocation where not.

Before claiming, make sure each export in the claim period is supported by:

• the sales contract or order with the overseas buyer;
• the customs declaration showing the goods cleared for export;
• non-cash payment from the buyer through a bank, in the forms the rules accept;
• an e-invoice for the export where the invoice rules require one.

Exports paid by offset against imports, paid by a third party, or not yet paid at the claim date are the usual weak points. The rules allow some of these arrangements with specific documents; if your group settles intercompany balances by netting, confirm the documentation before you claim, not after the query arrives.

New investment projects: timing and separation

A project in its investment phase can pay significant VAT on construction work, equipment and services years before it generates output VAT. The law allows a refund in that phase, subject to conditions linked to the project's licensing and capital. Two practical points decide most outcomes:

1. Keep the project's input VAT separate from any existing business of the same company. A company that already operates one plant and builds a second must track the new project's VAT on its own, from the first invoice.
2. Keep the investment documents consistent. The project's scope and capital in the investment registration, the contracts, and the invoices should tell the same story. A claim for equipment that does not appear in the licensed scope invites questions.

Check the current conditions on capital contribution and licensing before the first claim. Projects in sectors that require conditions to operate may need those conditions met before a refund is allowed.

How a claim is handled

Refund claims are filed through the company's e-tax account. Under the Law on Tax Administration (Law 38/2019/QH14), the tax office classifies each claim into one of two tracks:

Which track applies depends on risk criteria and on the claimant's history; a company claiming for the first time should expect its claim to be checked before payment. From 1 July 2026, tax administration procedures are also governed by Decree 252/2026/ND-CP and Circular 89/2026/TT-BTC, and Circular 94/2026/TT-BTC covers compliance and risk management. We name them so you know where to look; confirm the current procedure and timelines in the texts before planning cash flow around a refund date.

What delays a claim

• Supplier verification. The tax office may verify invoices with the tax offices managing your suppliers. If a supplier is not operating at its registered address, or has ceased operating without closing its tax code, the related input VAT can be held back while this is resolved.
• Payment gaps. Purchase invoices of VND 5 million or more without non-cash payment evidence, or export sales without bank receipts.
• Mismatched data. Invoices in the claim that differ from the e-invoice portal, customs data that differs from the export schedule, or carried-forward balances that differ from the tax office's records.
• Mixed activities. A claim that does not show how input VAT was split between exports and domestic sales, or between the new project and existing operations.
• Outstanding tax debts. Amounts the system treats as unpaid can be offset against the refund, so reconcile your e-tax account first.

Most of these are fixed by doing monthly what the claim will need anyway: reconcile purchases to the e-invoice portal, attach payment references, and check supplier statuses when you onboard them.

Preparing a claim file that holds up

Treat the claim as the start of an audit. A practical file contains:

1. A schedule of input invoices for the period, each with supplier tax code, status checked, and payment reference.
2. A schedule of exports with contract, customs declaration and bank receipt references, or, for a project, a schedule of project costs tied to contracts.
3. The allocation workings, if the company has mixed activities.
4. A reconciliation of the carried-forward balance from the last return to the claim amount.
5. A short cover note explaining anything unusual — a large one-off purchase, a new supplier, an intercompany netting arrangement.

Accounting documents used directly for bookkeeping and preparing financial statements must be kept for at least 10 years under the Law on Accounting, and refund audits can reach back several years. Keep the file in a form someone other than the preparer can follow.

Restructuring, closure and change of ownership

Refunds are not only for companies that are growing. When a company is converted, merged, split, dissolved or goes bankrupt with input VAT still uncredited, the law provides a refund case for the surplus. In practice this case is often handled late and badly, because the people who understood the VAT history have already left.

A few points make the difference:

• Decide early whether the surplus transfers or is refunded. In a merger, the receiving company may take over the VAT position rather than the merging company claiming a refund. Which route applies depends on the form of the transaction; confirm it with your adviser before signing.
• Close the VAT file before the tax code. A dissolving company must settle its tax obligations before its tax code can be closed. A refund claim, supplier verification and offset of outstanding amounts all happen inside that process, so start it early.
• Keep the records beyond closure. Someone must hold the accounting records for the retention period after the company ends, and the tax office can still review the final periods.

A company that stops trading without completing these steps may end up with a status showing it has ceased operating without closing its tax code — status 03 on the taxpayer lookup. That status is visible to every customer and supplier that checks, and it complicates the refund further.

Where to check your own position

Your company's e-tax account shows returns filed, the input VAT carried forward in the tax authority's records, refund claims submitted and their status. The e-invoice portal shows purchase invoices under your tax code; the taxpayer information lookup shows supplier statuses. Check all three in the month before you claim.