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VCN - Vietnam Chamber of Commerce and Industry (VCCI) has made comments on the content regarding the draft Decree on invoices and vouchers.
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The draft decree on invoices and documentsliststhat organizations, individuals and enterprises selling goods and providing services are subject to using electronic invoices. VCCI said that this provision did not cover all subjects selling goods and providing services because in reality, there are non-business organizations but they provide payable services and goods with business nature such as: profit-making service delivery units, public service providers for the State but having business activities of collecting money; foreign contractors applying the declaration method and the mixed method; and project management boards.
Therefore, to cover all goods and service providers, VCCI said that the following subjects should be added: organizations that are not businesses but engage in business activities (for example: project management boards, foreign contractors applying the declaration method and mixed method; public service delivery units with irregular revenue).
Regarding the regulation on invoice types (Article 7), for sales invoices for organizations and individuals declaring value-added tax by direct method, the draft decree states that: "Sales invoices are invoices issued when selling goods and services for organizations and individuals declaring value-added tax by direct method, specifically: a)organizations and individuals declaring and calculating value-added tax by the direct method when selling goods, providing services, exporting goods to non-tariff areas and cases regarded as exports, exports ofgoods or provision of services abroad.”
According to VCCI, this regulation leads to the understanding that organizations and individuals declaringtax by direct method when selling goods and services to the domestic marketdo not have invoices or do not know what type of invoice to use, because the draft does not specify the type of invoice for those organizations and individuals selling goods or providing services to the domestic market.
VCCI commented that the above regulation should be amended to "sales invoicesareinvoices issued when selling goods and services: a) organizations and individuals declaring, calculating tax when selling goods or providing services to the domestic market, exporting to non-tariff areas and cases regarded as exports, exports of goods or provision of services abroad”.
Besides, with other documents, VCCI said that the draft regulations are not clear because according to the draft regulations: “the documents are printed, issued, used and managed as invoices including goods delivery and internal transport note, goods delivery note for goods sent to agents”.
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There are many different meanings for businesses because it is unclear whether the goods delivery and internal transport note and goods delivery note for goods sent to agents will be applied in electronic form or self-printed form.
Whether businesses need to register, issue and transmit as an electronic invoice. Therefore, the above issues need to be clarified.
By Thuy Linh/ Huyen Trang