Zero-rated VAT on exports and sales to export processing enterprises: the evidence you need

Under Law 48/2024/QH15 on Value Added Tax, goods exported from Vietnam, services consumed outside Vietnam and sales into non-tariff zones — including to export processing enterprises (EPEs) — can carry VAT at 0%. The supplier still credits input VAT on its costs, which is what makes the rate valuable. But 0% is not automatic: each sale must meet documentary conditions, and a sale that fails them is taxed at the rate that would apply domestically.

For foreign-invested manufacturers and service centres, most of the revenue may sit under this rate. That makes the evidence a revenue-scale issue, not an administrative detail. This guide sets out what qualifies, what does not, and the file you should hold for each type of sale.

What can qualify for 0%

• Exported goods: goods sold to buyers outside Vietnam and cleared through customs for export.
• Sales into non-tariff zones: goods sold to enterprises in non-tariff zones, such as EPEs, are treated like exports for VAT when the conditions are met.
• Exported services: services supplied to overseas organisations or individuals and consumed outside Vietnam, and certain services supplied to enterprises in non-tariff zones.
• International transport and certain related services.

The law and Decree 181/2025/ND-CP set the detailed scope and a list of exceptions. Read the current list before pricing a new contract: some items that look like exports are expressly excluded, and some excluded items look like ordinary services.

The evidence for exported goods

For goods, the file behind a 0% sale usually has four parts:

1. The contract or order with the foreign buyer, or with the enterprise in the non-tariff zone.
2. The customs declaration showing the goods cleared for export, or the declaration required for sales into the zone.
3. Non-cash payment: the buyer's payment received through a bank, in one of the forms the rules accept.
4. The invoice required under the invoice rules for the sale.

The payment condition is the one groups trip over. Exports settled by netting against the parent's supplies, paid by a group treasury company rather than the buyer, or still unpaid at the declaration date need either the specific documents the rules accept for those situations or a clear plan for when payment arrives. If the rules do not accept the arrangement, the 0% rate is at risk even though the goods did leave the country.

Exported services: "consumed outside Vietnam" is the test

For services, the question is not who the customer is but where the service is consumed. A Vietnamese engineering centre designing products for its overseas parent may qualify. A Vietnamese company that provides hotel rooms, meals, local transport or event services to a foreign company's staff visiting Vietnam does not, even though the invoice goes to a foreign address — those services are consumed in Vietnam.

Evidence that helps for exported services:

• A contract that describes the service and states where the results are used.
• Deliverables that show the service was delivered to and used by the overseas customer — reports, designs, code releases, support logs.
• Payment received from the overseas customer through a bank.

Shared service centres, software development units and design centres of foreign groups often rely on this rule for most of their revenue. Map each service line against the exception list once, document the conclusion, and revisit it when the service changes.

Export processing enterprises and non-tariff zones

EPEs are a common feature of Vietnam's manufacturing base. For VAT, the relationship runs in both directions:

For a domestic supplier, the practical risk is a sale invoiced at 0% without the customs declaration the rules require for goods moving into the zone. For the EPE, the risk is in the other direction: domestic purchases invoiced with VAT that it cannot credit in the usual way. Agree with each counterparty, in writing, how sales will be documented before the first shipment.

Common reasons a 0% sale is reclassified

• The customs declaration is missing, cancelled or does not match the invoice.
• The buyer paid in cash, through a third party without the documents the rules require, or not at all.
• The service was consumed in Vietnam, or falls on the exception list.
• The contract was signed after the service was performed, or does not describe the service actually supplied.
• Goods were sold to a domestic company for later export by that company — the first sale is generally domestic.

When a sale is reclassified, output VAT at the domestic rate falls on the supplier, usually without the chance to collect it from the foreign buyer. The contract should therefore say who bears VAT if the 0% conditions are not met.

Contract terms that protect the 0% position

Most 0% problems could have been prevented in the contract. When the finance team reviews an export or cross-border service agreement, a few clauses deserve attention:

1. Description of the service and place of use. Describe what is delivered and where the customer uses it. Generic wording such as "support services" makes the consumed-abroad test hard to prove.
2. Payment route. State that payment is made by the buyer by bank transfer to the supplier's account. If a group treasury company will pay, say so and attach the arrangement the rules accept.
3. VAT clause. Say that prices exclude Vietnamese VAT, that the parties expect the 0% rate to apply, and who bears VAT if the conditions are not met.
4. Documents. Oblige the buyer to provide what you need from its side — acceptance records, confirmations of delivery, customs documents for goods moving into a non-tariff zone.
5. Dates. Sign before the service starts. A contract dated after performance is one of the reasons a 0% sale is reclassified.

For intercompany agreements, the same clauses matter, and they also support the transfer pricing file. A group template written for another country rarely covers the Vietnamese points without adaptation.

Building the evidence into the process

The file for a 0% sale is easiest to build when it is assembled as the sale happens, not at year end. Some practical controls:

• Link customs and invoicing data. Each export invoice should carry a reference to its customs declaration, and the monthly VAT schedule should flag invoices without one.
• Track receipts against export invoices. An ageing report of unpaid export invoices is also a list of 0% sales at risk.
• Keep a service map. For each service line sold abroad, record why it qualifies and who approved the conclusion.
• Review intercompany settlement. If the group settles by netting, confirm the documents with your adviser and file them with the VAT working papers.

These controls also support a later refund claim: exporters are among the main refund claimants, and the same documents are examined in both cases.

Where to check your own position

The customs electronic system holds your export declarations; the e-invoice portal shows the invoices issued under your tax code; your company's e-tax account shows the VAT returns filed, including the 0% sales declared. Reconcile the three every month. If they disagree, the tax office will see the same disagreement when it reviews a refund or an audit file.