CIT Deductible Expenses: Invoices, Vouchers, Bank Transfers

A business expense that is reasonable for operations can still be excluded from deductible costs if it lacks an invoice or a bank transfer voucher, or if it falls into the non-deductible list. The result is higher taxable income and higher corporate income tax (CIT), with late-payment charges if the tax authority makes an adjustment.

Quick answer: an expense is deductible if it meets three conditions: it is actually incurred in connection with business activities; it is supported by valid invoices and vouchers; and, for a single transaction of 5 million VND or more, it is paid by non-cash method. It must also not fall into the non-deductible list in Article 10 of Decree 320/2025/NĐ-CP.

Which expenses are deductible for CIT?

Clause 1, Article 9 of the Corporate Income Tax Law 67/2025/QH15 and Clause 1, Article 9 of Decree 320/2025/NĐ-CP set three conditions at the same time:

Actual expense incurred in connection with the business’s production and business activities.
Sufficient invoices and vouchers as required by law.
Non-cash payment voucher for the purchase of goods, services and other payments made in a single transaction of 5 million VND or more.

An expense must also not fall into the non-deductible list in Article 10 of Decree 320/2025/NĐ-CP. Article 3 of Circular 20/2026/TT-BTC (effective 12/3/2026, applying from the 2025 tax period) sets additional documents for some specific expenses: training expenses need a decision to send the trainee and a diploma or certificate of attendance, as well as an employment contract or a financial regulation that provides for them; sponsorship requires a confirmation minute in Form No. 01/TNDN; and losses caused by natural disasters need an inventory minute and a stock-in and stock-out list.

What counts as a valid invoice or voucher?

A seller of goods or services must issue an e-invoice to the buyer under Decree 254/2026/NĐ-CP (see the article e-invoices for businesses). For the buyer, three points matter:

Invoices from cash registers: an expense for goods or services supported by an invoice issued from a cash register connected to the tax authority data (which can be checked in the tax administration information system) is treated as having sufficient invoices and valid vouchers when determining tax obligations (Point c, Clause 9, Article 8, Decree 254/2026/NĐ-CP).
Purchases from people without invoices: allowed only in the cases listed in Point b, Clause 1, Article 9 of Decree 320/2025/NĐ-CP. These include agricultural, forestry and fishery products sold directly by the producer, handicraft products, scrap collected directly by the person who gathered it, household and individual items, and goods or services of individuals or household businesses with revenue below the VAT threshold. In these cases the business needs a payment voucher and a purchase schedule signed by its legal representative or an authorized person.
Incorrect invoices: corrected by notice, adjustment or replacement under Article 10 of Circular 91/2026/TT-BTC. Details are in the article on e-invoices referred to above.

Non-cash payment: the threshold and special cases

Point c, Clause 1, Article 9 of Decree 320/2025/NĐ-CP provides:

A single transaction of 5 million VND or more: a non-cash payment voucher is required under the VAT rules.
Several payments on the same day: purchases from one seller, each under 5 million VND but totaling 5 million VND or more in the day, are deductible only with a non-cash payment voucher (Point c1).
Staff purchasing on the business’s behalf: for a transaction of 5 million VND or more, if the employee pays by a non-cash service, the expense is still deductible when there is an invoice or voucher; the financial regulation or internal rules must permit the employee to pay; and the business reimburses the employee (Point c2).
Not yet paid when the expense is recognized: the expense is included in costs. When the amount is paid in cash, the business must declare it and reduce the expense in the tax period in which the payment is made, even if an inspection or audit has already been decided for that period (Point c3).

Illustration: a shipment of goods worth 12.000.000 VND with a valid invoice but paid in cash does not meet the conditions. Three purchases from the same seller in one day, each of 2.500.000 VND (7.500.000 VND in total), also need a non-cash payment voucher.

Which expenses are commonly not deductible?

Expense	Basis in Decree 320/2025/NĐ-CP
Expenses that do not meet the invoice, voucher or non-cash payment conditions	Clause 1, Article 10
Administrative penalties, including late tax payment charges	Clause 2, Article 10
Direct staff welfare above one month of actual average salary in the year	Point d, Clause 4, Article 10
Amounts above 5 million VND per month per person paid for supplementary retirement insurance, voluntary retirement insurance or life insurance; this is also non-deductible if the business has not fully met its compulsory insurance obligations, even if arrears remain	Point đ, Clause 4, Article 10
Depreciation of fixed assets not used for business or without documents proving ownership; depreciation of passenger cars with 9 seats or fewer corresponding to the cost above 1,6 billion VND per vehicle (except cars used in passenger transport, tourism, hotels, and demonstration and test drives for car dealerships)	Clause 6, Article 10
Wages and bonuses recorded but not paid, or not supported by a payment voucher; wages and bonuses without specified conditions and benefit levels in the labor contract or regulations	Points a and b, Clause 8, Article 10
Salary of a sole proprietor, and of the owner of a single-member limited liability company owned by one individual; remuneration of members who do not directly manage the business	Point d, Clause 8, Article 10
Input VAT deducted; corporate income tax; personal income tax (except where the labor contract states that wages do not include tax); late payment charges	Clause 12, Article 10
Expenses not corresponding to taxable revenue; overtime above the limit set by labor law; advertising for banned products	Clauses 22 and 23, Article 10

Wages and bonuses not paid by the deadline for filing the finalization return are not deductible, unless the business sets up a reserve for wages of no more than 17% of the wage fund actually used and does not make a loss after setting it aside (Point c, Clause 8, Article 10). For compulsory insurance debts, see the article on late BHXH contributions.

How can a business reduce the risk of disallowed expenses at finalization?

Match each transaction of 5 million VND or more against its invoice and bank transfer voucher.
Review purchases made on behalf of the company by employees, travel expenses, welfare, and wages and bonuses against the financial regulation and labor contracts.
Show non-deductible items separately when preparing the return. For the tax rate and filing deadline, see the article CIT 2026.

How Thái Tín supports deductible expense review

Thái Tín helps businesses review vouchers before the finalization period and connects them with accounting and tax partners who handle the filings:

Classify expenses by the three conditions and the non-deductible list to identify items at risk of being disallowed.
Prepare a plan to add missing invoices and supporting documents, and connect the business with specialist partners who prepare or correct the finalization return.

To start, please send us a summary of the main expenses and the payment methods you use, with personal information removed, so that we can prepare a plan and connect you with the right specialist partner.

Questions and answers

What conditions must an expense meet to be deductible for CIT?

Under Clause 1, Article 9 of Decree 320/2025/NĐ-CP (guiding Article 9 of Corporate Income Tax Law 67/2025/QH15), apart from the non-deductible items in Article 10, an expense must meet three conditions: it is actually incurred and relates to production and business; it is supported by sufficient invoices and vouchers as required; and, for the purchase of goods, services and other payments made in a single transaction of 5 million VND or more, it is paid by a non-cash voucher.

If a business buys goods worth 12 million VND with a valid invoice but pays in cash, is the cost deductible?

No, it does not meet the conditions. Point c, Clause 1, Article 9 of Decree 320/2025/NĐ-CP requires a non-cash payment voucher for a single transaction of 5 million VND or more. An expense that does not meet the conditions in Clause 1, Article 9 is non-deductible (Clause 1, Article 10). The non-cash voucher rule applies from the effective date of the decree, 15/12/2025 (Point b, Clause 1, Article 24).

What happens when a business buys from an individual or small household business that has no invoice?

This is allowed only in the cases listed in Point b, Clause 1, Article 9 of Decree 320/2025/NĐ-CP. These include agricultural, forestry and fishery products sold directly by the producer, scrap collected directly by the person who gathered it, household and individual items, and goods or services of individuals or household businesses with revenue below the VAT threshold. In such cases, the business must hold a payment voucher and a purchase schedule signed by its legal representative or an authorized person, and any transaction of 5 million VND or more with the same household or individual on the same day must be paid by non-cash method.

Are administrative penalties and late tax payment charges deductible?

No. Point b, Clause 2, Article 9 of the CIT Law and Clause 2, Article 10 of Decree 320/2025/NĐ-CP exclude administrative penalties from deductible expenses, including those for violations of traffic law, business registration, accounting and tax law (including late tax payment charges under the Law on Tax Administration), and other administrative fines.

What is the maximum deductible amount for staff welfare?

Welfare payments directly for employees (funerals, weddings, holiday trips, medical support, travel support for holidays, voluntary insurance and similar items) above one month of actual average salary in the tax year are not deductible (Point d, Clause 4, Article 10, Decree 320/2025/NĐ-CP). One month of average salary equals the total wage fund actually paid in the year divided by 12, or by the number of actual operating months if the business did not operate for the full 12 months (Point d.1).

Legal basis · verification date

Verified 20 October 2026 · next review 18 January 2027. The content is general guidance and does not replace advice for a specific case.

Corporate Income Tax Law 67/2025/QH15 (effective 01/10/2025, applying from the 2025 tax period; Official Gazette Nos. 965 and 966, 24/7/2025): Article 9 (deductible and non-deductible expenses), Clause 1, Article 19.
Decree 320/2025/NĐ-CP (issued and effective 15/12/2025, applying from the 2025 tax period; Official Gazette Nos. 1737 and 1738, 28/12/2025): Article 9 (conditions for deductible expenses, non-cash payment, purchases from people without invoices), Article 10 (non-deductible items: Clause 2, administrative penalties; Point d, Clause 4, staff welfare; Point đ, Clause 4, voluntary insurance; Clause 6, depreciation; Clause 8, staff remuneration; Clause 12, taxes; Clauses 17 and 22, 23), Point b, Clause 1, Article 24 (non-cash voucher rule applies from the decree's effective date).
Circular 20/2026/TT-BTC (issued 12/3/2026, effective 12/3/2026, applying from the 2025 tax period; Official Gazette No. 179, 03/4/2026): Article 3 (documents for certain expenses deductible under Points b and c, Clause 1, Article 9 of the CIT Law, such as training, sponsorship and losses caused by natural disasters).
Decree 254/2026/NĐ-CP (issued 30/6/2026, effective 01/7/2026): Point c, Clause 9, Article 8 (invoices issued from cash registers as valid invoices and vouchers).
Decree 141/2026/NĐ-CP (29/4/2026) only adds Clause 15 to Article 4 of Decree 320/2025/NĐ-CP (exemption based on revenue) and does not amend Articles 9 or 10. Checked for amendments on 20/10/2026: the CIT Law was amended by Law 09/2026/QH16, which adds Clause 14a to Article 4 (exemption) and does not change Article 9. No amendment to the articles used in this article has been found.