Official Letter 7269/CT-QLTT: Tax Department Replies to VCCI on Documents for Buying Fish from Fishing Households, No Seller Signature Needed on the Purchase List

Companies that buy agricultural, forestry and fishery products directly from local people often meet one problem: the seller does not want to sign a confirmation or accept a bank transfer for fear of creating a tax liability, while the company needs documents to count the expense. Official Letter 7269/CT-QLTT of the Tax Department, signed on 30/9/2026, addresses exactly this situation after VCCI forwarded a petition from the traditional fish sauce association.

Quick answer: the Tax Department considers that current law already gives guidance. Under Point b, Clause 1, Article 9 of Decree 320/2025/NĐ-CP, buying seafood sold directly by the fisher requires two things: proof of payment to the seller and a Purchase List signed by the company’s representative. The list does not need the seller’s signature. When the value purchased from a household or individual in a day is 05 million VND or more, payment must be non-cash. This is a reply to a specific petition, not a legal normative document.

What is the VCCI petition?

Official Letter 7269 replies to VCCI on the petition in Official Letter 1921/LĐTM-PC, part of a consolidated report on businesses’ difficulties in August 2026. According to the petition, many households with fishing vessels do not sign confirmations of fish sales to fish sauce producers because they fear that revenue above the threshold will mean paying tax without an invoice. They also refuse to accept bank transfers, leaving producers without documents to prove the purchase. VCCI asked local tax authorities in fish sauce craft villages to give guidance and support.

How does the Tax Department reply?

The Tax Department concludes that current law already guides the petitioned issue, notes it and informs VCCI, and will continue to coordinate in raising awareness and guiding households, individuals, vessel owners and the organizations that buy and produce fish sauce.

Thái Tín has read the original text of Point b, Clause 1, Article 9 in the Official Gazette. The decree lists several cases, and the phrase “excluding the cases mentioned above” only separates the group of households below the VAT threshold from the groups before it; the requirement for “proof of payment” and the Purchase List applies to the whole list, as Crowe Vietnam also presents. Thái Tín has not been able to read the original letter. For details, see the article on deductible expenses for corporate income tax.

What the letter does not say

• The part of the content read does not state that vessel owners are exempt from, or must pay, tax. The obligation depends on each household’s revenue and type of business; for the revenue thresholds and calculation for business households and individuals, see the article on business household tax from 2026.
• The part of the content read does not say it applies only to fish sauce. That is the situation petitioned; Article 9 applies by group of sellers, so other purchasing companies need to determine for themselves which case they fall into.
• A purchase list and proof of payment do not replace the other conditions for a deductible expense: actually incurred and related to production and business.

What companies buying directly should do

1. Classify the seller: a person who directly catches, farms or produces and sells, or a trader or business household that buys and resells.
2. Prepare the purchase list on Form 02/TNDN (Circular 20/2026/TT-BTC), signed and taken responsibility for by the company’s representative or authorized person. If someone else signs, a clear authorization document is needed. The method of preparation is similar to the form described in the article on affiliate marketing.
3. Keep proof of payment for each seller. Add up the value purchased by day and by seller; from 05 million VND or more, payment must be non-cash.
4. Keep additional evidence of the real goods: weighing slips, warehouse receipts, delivery records, a log of fishing vessels arriving at port.
5. For suppliers that are households with large revenue, ask for e-invoices as set out in the article on e-invoices for businesses 2026.

Common misunderstandings

• Thinking a purchase list is enough: the decree requires proof of payment as well, even when buying from fishers directly.
• Thinking the seller must sign the list: the letter states the seller’s confirming signature is not required.
• Turning a reply given to one sector into a general rule: read the original provision.

How Thái Tín can help

Thái Tín is the point of contact that helps a company check its purchasing documents and connects it with accounting and tax partners:

• Classify the seller groups and the documents needed for each group.
• Check the purchase list template, the payment process and warehouse records.
• Connect specialist partners to handle the file at settlement or when dealing with the tax authority.

Please send us your current purchasing model (with sellers’ personal information removed) so that Thái Tín can prepare a list of documents to add.

Cross-check sources and date: original text of Decree 320/2025/NĐ-CP (Official Gazette), LuatVietnam, Crowe Vietnam and Tax and Customs Magazine, read on 02/11/2026; the original letter has not been read.

Questions and answers

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