Accounting & Tax

Three Tax Department Official Letters of October 2026 on VAT and Invoices: Export Processing Enterprises, Services Performed Abroad, the KTPVDC Code

Verified 2 November 2026 · next review 31 January 2027

1

Official Letter 7813/CT-QLNT (16/10/2026): goods and services outside the scope of the VAT Law must still be issued an e-invoice, with the code KTPVDC entered in the tax rate field under Decision 1233/QĐ-CT, and the revenue declared at indicator [34a] of return 01/GTGT.

2

Official Letter 7634/CT-QLNT (14/10/2026): international transport support services that are not performed in Vietnam and not used for production, business or consumption in Vietnam are outside the scope of the VAT Law; the seller still issues an invoice to the buyer under Clause 1, Article 4 of Decree 254/2026/NĐ-CP.

3

Official Letter 7552/CT-QLNT (12/10/2026): an export processing enterprise enjoys the policies for non-tariff zones only when customs confirms it meets the conditions for customs inspection and supervision; if the project changes its objective, the e-invoices already issued must be adjusted or replaced.

4

All three are replies to individual entities, not legal normative documents; Thái Tín has not read the full originals.

In October 2026 the Tax Department issued several official letters replying to individual companies on value added tax (VAT) and invoices. Three of them have replies that can be read clearly and are useful to accountants: 7552/CT-QLNT, 7634/CT-QLNT and 7813/CT-QLNT. All three reply to a specific entity and none is a legal normative document, so this article only draws out the points to note, with the legal basis for you to check.

Quick answer: (1) goods and services outside the scope of the VAT Law must still be issued an invoice, with the code KTPVDC in the tax rate field and the revenue declared at indicator [34a] of return 01/GTGT (Official Letter 7813); (2) international transport support services that are not performed in Vietnam and not used in Vietnam are outside the scope of the VAT Law (Official Letter 7634); (3) an export processing project that changes its objective must adjust or replace the invoices already issued (Official Letter 7552).

Official Letter 7813/CT-QLNT (16/10/2026): invoices and declaration for transactions outside the scope of the VAT Law

The letter is addressed to DHL Global Forwarding (Vietnam) Joint Stock Company. The Tax Department notes that these questions were already answered in Official Letter 5744/CT-CS of 10/8/2026, and then guides:

  • Issuing invoices: under Clause 5, Article 26 of Tax Administration Law 108/2025/QH15 and Clause 1, Article 4 of Decree 254/2026/NĐ-CP, the seller must issue an e-invoice when selling goods or providing services, except for cases exempted under Article 7 of that decree.
  • Tax rate on the invoice: under the appendix on invoice content of Decree 254/2026/NĐ-CP, it must be shown for each type of goods or service. Under Decision 1233/QĐ-CT of 27/8/2026 (item 9 of Appendix V), goods and services outside the scope of the tax law show the code “KTPVDC” in the tax rate field.
  • Declaration: this type of revenue is entered at indicator [34a] of return 01/GTGT (Circular 89/2026/TT-BTC); input tax is deducted under Article 23 of Decree 181/2025/NĐ-CP. Note: Clause 2 of Article 23 was amended and supplemented by Decree 144/2026/NĐ-CP from 20/6/2026, so accountants should check the version in force when allocating input tax.
  • The Tax Department asks the company to contact its directly managing tax authority for specific guidance.

A commonly confused point: “outside the scope” is different from “subject to 0% tax rate” or “not subject to tax”. Accountants should enter the correct code and the correct indicator. For how to issue and adjust invoices in general, see the article on e-invoices for businesses 2026; for the return form, see the article on tax return forms under Circular 89.

Official Letter 7634/CT-QLNT (14/10/2026): international transport support services

The letter is addressed to Viettel Logistics One-Member Limited Liability Company, in reply to its document 649/LOG-TC of 12/8/2026. The source page does not show the full question; from the reply, the company asked about international transport support services such as handling, customs, loading, lifting and packing for Vietnamese companies. The Tax Department replies:

  • If these services are not performed in Vietnam and not used for production, business or consumption in Vietnam, they are outside the scope of the VAT Law (basis: Article 3 of Law 48/2024/QH15).
  • On invoices, the seller must issue an invoice to the buyer; for services performed abroad, the company issues invoices under Clause 1, Article 4 of Decree 254/2026/NĐ-CP.
  • The company should act on the rules and its actual situation.

The conclusion is tied to the condition “not performed in Vietnam and not used in Vietnam”. Logistics companies need to determine, for each service, where it is performed and where it is used, and should not extend the answer to the whole logistics service group.

Official Letter 7552/CT-QLNT (12/10/2026): an export processing enterprise changing its objective

The letter is addressed to the Bac Ninh City Tax Office, in reply to Official Letter 6215/BNI-QLDN1 of 15/5/2026. From the reply, the situation is a company issued an investment certificate with the objective of an export processing enterprise that, during construction, moved to activities not matching that objective. The Tax Department states:

  • An export processing enterprise enjoys investment incentives and the tax policies for non-tariff zones from the time of the investment objective stated in the certificate issued by the competent authority.
  • After construction is completed, the company must be confirmed by customs as meeting the conditions for customs inspection and supervision before it officially operates; otherwise it does not enjoy the tax policies applicable to non-tariff zones.
  • Where the objective changes, the supplier and the company adjust or replace the e-invoices already issued under Decree 70/2025/NĐ-CP; from 01/7/2026, under Decree 254/2026/NĐ-CP (replacing Decree 123/2020 and Decree 70/2025) and Circular 91/2026/TT-BTC, and the company should re-check the original text.

The letter cites many bases on the 0% tax rate, conditions for application and deduction under Decree 181/2025/NĐ-CP. A company running an export processing project should contact its managing tax and customs authorities, since Thái Tín has not read these three letters in full.

What a company needs to do

  1. Check invoices already issued for transactions outside the scope of the VAT Law: has the code KTPVDC been entered, and has the revenue gone into indicator [34a]?
  2. For services with a foreign element, record where the service is performed and where it is used, to support the classification.
  3. Export processing or non-tariff zone projects: check the customs inspection and supervision confirmation and the objective on the investment certificate.
  4. Invoices issued at the wrong time or of the wrong type: adjust or replace them under current rules and keep the record of agreement.
  5. Check periodic filing obligations in the article on recurring tax obligations of a company.
  6. For ordinary taxable transactions, see also the reduction in the article on VAT 2025-2026 with the 8% reduction.

At the end of September 2026 the Tax Department also issued Official Letter 7269/CT-QLTT replying to VCCI on purchasing documents for goods from fishers.

Common misunderstandings

  • Assuming a letter sent to another company applies immediately: look at the situation, the subject and the basis.
  • Not issuing an invoice because the transaction is outside the scope of the VAT Law: Official Letter 7813 states an invoice must still be issued, except in exempt cases.
  • Mixing up the KTPVDC code with the 0% tax rate: they are two different concepts.

How Thái Tín can help

Thái Tín is the point of contact that helps a company check invoices and VAT returns and connects it with accounting and tax partners:

  • Classify transactions by the scope of the VAT Law.
  • Check how the tax rate, the code on the invoice and the declaration indicator are entered.
  • Connect specialist partners to adjust invoices and deal with the tax authority.

Please send us a description of the transaction (with counterparty information removed) so that Thái Tín can prepare a list of what needs to be done.

Cross-check sources and date: document pages of LuatVietnam, read on 02/11/2026; the full original letters were not accessed.

Questions and answers

Do these three official letters apply to all companies?

No. Each letter replies to a specific entity: 7552 to the Bac Ninh City Tax Office about an export processing project, 7634 to Viettel Logistics One-Member Limited Liability Company, and 7813 to DHL Global Forwarding (Vietnam) Joint Stock Company. Official letters are not legal normative documents; other companies should only use them as a reference for interpretation and check the original legal basis.

Must an invoice be issued for goods and services outside the scope of the VAT Law?

According to Official Letter 7813/CT-QLNT, yes: the seller must issue an e-invoice when selling goods or providing services, except for cases exempted under Article 7 of Decree 254/2026/NĐ-CP. The tax rate field of the invoice shows the code KTPVDC, meaning outside the scope of the tax law.

Where is revenue outside the scope of the VAT Law declared?

According to Official Letter 7813, at indicator [34a] of VAT return form 01/GTGT issued with Circular 89/2026/TT-BTC. Deduction of input VAT follows Article 23 of Decree 181/2025/NĐ-CP; Clause 2 of that article was amended and supplemented by Decree 144/2026/NĐ-CP from 20/6/2026.

Are handling, customs and loading services performed abroad subject to VAT?

According to Official Letter 7634, if these services are not performed in Vietnam and not used for production, business or consumption in Vietnam, they are outside the scope of the VAT Law. The letter replies to a specific company, so a company should compare each transaction with Article 3 of VAT Law 48/2024/QH15.

How are invoices already issued handled if a project registered as an export processing enterprise changes its objective?

According to Official Letter 7552, the supplier and the company must adjust or replace the e-invoices already issued under Decree 70/2025/NĐ-CP; from 01/7/2026, invoice rules follow Decree 254/2026/NĐ-CP (replacing Decree 123/2020 and Decree 70/2025) and Circular 91/2026/TT-BTC. Each file should be raised with the managing tax authority.

Legal basis · verification date

Verified 2 November 2026 · next review 31 January 2027. The content is general guidance and does not replace advice for a specific case.

  1. Official Letter 7813/CT-QLNT of 16/10/2026 of the Tax Department replying to DHL Global Forwarding (Vietnam) Joint Stock Company on tax and invoice policy. The full original was not accessed; the content was read on the LuatVietnam document page. The letter replies to one entity and is not a legal normative document.
  2. Official Letter 7634/CT-QLNT of 14/10/2026 of the Tax Department replying to Viettel Logistics One-Member Limited Liability Company on VAT and invoices. The full original was not accessed; read on the LuatVietnam document page, which does not display the full question.
  3. Official Letter 7552/CT-QLNT of 12/10/2026 of the Tax Department replying to the Bac Ninh City Tax Office on VAT and invoices for a project registered as an export processing enterprise. The full original was not accessed; read on the LuatVietnam document page, which does not display the full question.
  4. Documents cited by the letters (Thái Tín has not opened each in full): Tax Administration Law 108/2025/QH15 (Clause 5, Article 26); VAT Law 48/2024/QH15 (Articles 3 and 9); Decree 254/2026/NĐ-CP (Clause 1, Article 4, Article 7, appendix on invoice content); Decree 181/2025/NĐ-CP (Articles 17, 18, 23); Decree 70/2025/NĐ-CP; Circular 91/2026/TT-BTC; Circular 89/2026/TT-BTC; Decision 1233/QĐ-CT of 27/8/2026 (Appendix V, item 9); Official Letter 5744/CT-CS of 10/8/2026. Decree 254/2026/NĐ-CP and Circular 91/2026/TT-BTC were issued on 30/6/2026 and took effect on 01/7/2026; Decree 254 replaces Decree 123/2020/NĐ-CP and Decree 70/2025/NĐ-CP.
  5. Amendment check: Law 149/2025/QH15 (from 01/01/2026) does not amend Article 3 and only amends Clause 5, Article 9 of Law 48/2024/QH15, per Consolidated Text 12/VBHN-VPQH on the Government Electronic Portal. Decree 359/2025/NĐ-CP (from 01/01/2026) adds Clause 1b to Article 4 and repeals Clause 3, Article 37 and Clause 3, Article 39 of Decree 181/2025/NĐ-CP. Decree 144/2026/NĐ-CP (from 20/6/2026) amends Point a and adds Point c to Clause 2, Article 23 of Decree 181/2025/NĐ-CP. The full text of these two decrees was not read; read via hethongphapluat, EY (5/2026) and MISA meInvoice (07/5/2026).

Official texts and standards