(UPDATED) VAT Refund Vietnam for Foreigners: A Guide to How to Claim VAT and Tax Relief

For a foreign-invested company in Vietnam, an accumulated input value-added tax balance can tie up a significant amount of working capital. A refund may release that cash, but an excess VAT balance does not automatically create a right to repayment. The company must fall within a statutory refund category and support the claim with consistent invoices, accounting records, payment evidence and, where relevant, customs and investment documents. 

Vietnam’s current framework is centred on the Law on Value-Added Tax No. 48/2024/QH15, effective from 1 July 2025, as subsequently amended. Decree No. 181/2025/ND-CP provides detailed implementation rules and has itself been amended, including by Decree No. 359/2025/ND-CP and Decree No. 144/2026/ND-CP. From 1 July 2026, the new tax-administration framework and Decree No. 252/2026/ND-CP also govern the processing and risk classification of refund applications. 

The practical question for a finance team is therefore not simply how much input VAT appears in the ledger. It is whether that VAT belongs to an eligible activity, has been recorded in the correct refund period and can withstand a transaction-level review. 

Explore our Tax Advisory service: Tax Advisory | Ascentium Vietnam

When can a business claim a VAT refund in Vietnam

The principal corporate refund routes are exports, qualifying investment projects, businesses exclusively supplying goods or services subject to the 5 percent VAT rate, and certain cases involving dissolution or bankruptcy. Separate rules cover official development assistance, non-refundable aid, diplomatic privileges and other prescribed situations. 

Input VAT that does not fall within a refund category is generally carried forward for deduction against future output VAT. Companies should avoid treating a large debit balance as an expected cash receivable until eligibility has been tested. 

Read More: Value-Added Tax in Vietnam: Guide to Navigating VAT for Business Success

VAT refunds for exporters 

An exporter may generally apply when eligible input VAT attributable to exported goods or services remains uncredited at VND300 million or more during a monthly or quarterly refund period. Where a company has both export and domestic revenue, it must first identify the VAT attributable to exports and offset the relevant balance against VAT payable on domestic activities. 

If the input VAT cannot be separately recorded, an allocation may be required based on the relationship between export revenue and total taxable revenue for the refund period. The refundable amount is also subject to the statutory ceiling linked to export revenue. Any amount that is not refundable under that ceiling may be carried forward for consideration in a later period. 

The accounting balance is only one part of the analysis. The company must be able to demonstrate that the export took place and that the transaction satisfies the applicable VAT conditions. Depending on the supply, this may involve the commercial contract, compliant VAT invoice, customs declaration, non-cash payment record, bill of lading and other transport or delivery evidence. 

Differences between the sales ledger, VAT return, customs declaration and bank receipt are common causes of questions. Before filing, exporters should reconcile these records invoice by invoice rather than rely on an aggregate spreadsheet prepared at the end of the period. 

VAT refunds for investment projects 

A company using the VAT credit method may qualify for a refund on a new or expanded investment project that remains in the investment stage. After the prescribed offset against VAT payable from existing business activities, eligible project input VAT must generally reach at least VND300 million. 

Project accounting is critical. Input VAT associated with construction, machinery, professional services and other investment expenditure should be separately identified from the company’s operating costs. If project and operational expenses are mixed in a single cost centre, the tax authority may require extensive reconciliation before accepting the amount claimed. 

The company should also confirm that its registered charter capital has been contributed in accordance with the applicable requirements and that it satisfies the conditions attached to any conditional business line. A failure in these areas can prevent a refund even where the invoices and VAT calculations appear correct. 

Timing matters once the investment phase ends. Under the VAT Law, a refund application for qualifying VAT incurred during the investment stage is generally subject to a one-year filing window after the project, phase or investment component is completed. For this purpose, completion is connected to the statutory revenue test, rather than merely the date shown on an internal project timetable. Finance and project teams should therefore agree in advance when an investment component is expected to move into operation.

The special rule for exclusively 5 percent rated activities 

A VAT refund in Vietnam is issued to a company when its total input VAT for 4 quarters or 12 months has not been deducted from iA business that exclusively produces goods or provides services subject to the 5 percent VAT rate may apply when uncredited input VAT reaches VND300 million after 12 consecutive months or four consecutive quarters. This is a specific refund route; it is not a general rule for every company carrying excess input VAT for a year. 

Businesses with mixed-rate activities need a separate analysis. The presence of 8 percent or 10 percent supplies, zero-rated exports or non-taxable activities can affect whether the company qualifies and how input VAT must be allocated.

Core conditions for a corporate refund 

The answer to “how can a company claim a VAT refund in Vietnam?” starts with establishing the correct refund category and building a consistent electronic dossier. Depending on the company and project, core corporate and accounting records may include: 

• The Investment Registration Certificate (IRC), where the project requires one; 

• The Enterprise Registration Certificate (ERC), or the relevant establishment or professional licence; 

• Compliant accounting books, electronic invoices, tax declarations and financial statements; 

• Details of the bank account registered under the company’s tax code and, for an investment project, evidence from the appropriate investment capital account where relevant; 

• Contracts, acceptance records, customs declarations and other transaction evidence required for the relevant refund route; 

• Proof that applicable non-cash payment conditions have been met; and 

• A complete, accurately reconciled electronic refund application. 

An IRC, company seal or investment capital account is not a universal requirement for every claimant. The dossier must reflect the entity’s legal form, licensing position and statutory refund category. Likewise, non-cash payment evidence is required where the VAT deduction and refund rules impose it, rather than indiscriminately for every transaction. 

Law No. 149/2025/QH15 amended the refund conditions from 1 January 2026. Accordingly, companies should use the current wording of the law and implementing regulations rather than checklists based only on the original 2024 VAT Law. 

Electronic invoices are an important part of this control environment, but businesses should avoid the simplistic assumption that an e-invoice is automatically sufficient. A technically valid invoice will not cure an unsupported purchase, an incorrect tax rate, an unrelated cost or a payment that does not satisfy the deduction rules.

How the VAT refund application is assessed?

VAT refund applications are submitted through the prescribed electronic tax channel to the competent authority. The authority classifies the file under the applicable risk-based process. A lower-risk file may be handled on a refund-first, audit-later basis, while specified higher-risk cases are reviewed before any refund is approved. 

• For an application classified as refund-first, audit-later, the statutory decision period is six working days from the tax authority’s formal acceptance of a complete dossier.  

• For an application subject to audit before refund, the statutory period is up to 40 days from formal acceptance.  

These are legal processing periods, not guaranteed dates for cash to reach the company’s account: the authority may request clarification, reject an ineligible amount or reclassify a refund-first file for pre-refund inspection where the law permits. 

Companies should plan cash flow conservatively. A statutory processing period begins only after formal acceptance and may not include time spent correcting an incomplete dossier or responding to information requests. Some businesses may experience prolonged disputes or legacy delays. 

Read Related: (2026 Update) Vietnam’s VAT Refunds: Broader Eligibility, Stricter Compliance Requirements

Why VAT refund claims are delayed 

Many delays originate before the application is filed. Frequent issues include: 

• Invoices that do not reconcile with the VAT return or general ledger; 

• Export invoices that cannot be matched to customs and payment records; 

• Insufficient evidence of non-cash payment; 

• Incorrect allocation between export and domestic activities; 

• Investment expenditure mixed with operating expenses; 

• Inconsistent project, licensing and capital-contribution records; 

• Costs that are not clearly connected to taxable business activities; and 

• Unresolved tax filings, liabilities or historical compliance questions. 

A large dossier can still be weak if the documents do not tell a consistent commercial story. The review should follow the transaction from contract and purchase through payment, accounting, VAT reporting and, for exports, delivery outside Vietnam.

A practical pre filing review 

Before submitting a claim, management should ask the finance team to complete five steps. 

First, identify the statutory refund category and calculate the period covered. Second, reconcile the proposed amount to the VAT returns and ledger. Third, test a transaction sample for invoice validity, payment and business purpose. Fourth, match export or investment evidence to the accounting entries. Finally, quantify amounts that should be removed, carried forward or reserved for further review. 

This process gives management a more reliable cash-flow forecast and reduces the risk of submitting an inflated claim. It also prepares the business to respond efficiently if the tax authority asks for transaction-level explanations. 

Explore our Tax Advisory service: Tax Advisory | Ascentium Vietnam

The temporary 8 percent VAT rate 

Vietnam’s temporary 2-percentage-point reduction continues until 31 December 2026 for eligible goods and services that would ordinarily be taxed at 10 percent. Certain categories remain outside the measure, including telecommunications, finance, banking, securities, insurance, real estate, specified metal and mining products, and goods or services subject to special consumption tax, apart from petrol. 

An exclusion from the reduction does not necessarily mean that the supply is VAT-exempt. The company must apply the normal VAT treatment for the relevant product or service. Classification errors affect both output VAT and the credibility of a refund claim, so businesses should retain the basis used to determine whether a supply qualifies for 8 percent.

Separate regime: VAT refunds for foreign visitors 

Corporate VAT recovery should not be confused with the refund scheme for foreigners and overseas Vietnamese taking purchased goods out of Vietnam. Since 1 July 2026, this visitor scheme has been governed by Circular No. 84/2026/TT-BTC and operates through an electronic system connecting participating retailers, customs authorities, tax authorities and refund-agent banks. 

Broadly, the goods must be purchased from a participating VAT-refund retailer, remain unused and in their original condition, be subject to VAT and be permitted to be carried on the relevant aircraft or vessel. They must not fall within prohibited or restricted export categories or the separate diplomatic VAT-refund regime. The retailer must issue the prescribed invoice-cum-VAT-refund declaration no more than 60 days before departure. Purchases from the same participating store on the same day must total at least VND2 million, including multiple eligible invoices aggregated for that store and day. 

These visitor rules do not determine whether a Vietnam-incorporated company may recover input VAT on exports, an investment project or another corporate refund category. 

Explore our Tax Advisory service: Tax Advisory | Ascentium Vietnam

How Ascentium Vietnam (formely InCorp Vietnam) can support a refund application 

VAT recovery requires more than completing an application form. Ascentium Vietnam can assess the relevant refund route, reconcile accounting and tax records, review invoices and payment evidence, identify gaps in export or investment documentation, and prepare an application that reflects the company’s actual transaction profile.  

Where a claim is likely to receive closer review, advance preparation is particularly valuable. Management can decide whether to correct records, exclude uncertain amounts or obtain additional evidence before the tax authority begins its examination.

Ascentium Vietnam (formerly InCorp Vietnam) is a trusted partner for foreign investors, providing comprehensive corporate advisory and outsourcing solutions across Vietnam and Asia. As part of Ascentium Group, we focus on providing transparent and reliable services to overseas clients in Vietnam and Asia.