Vietnam VAT Refund Changes: New Regulations for Export and 5% VAT Businesses Starting July 2025

Vietnam’s VAT refund framework underwent significant changes under Law 48/2024/QH15, Article 15 (effective July 1, 2025). The minimum refund threshold remains VND 300 million (~USD 12,000) in uncredited input VAT, as established by Law 48/2024/QH15, Article 15. Import-for-re-export operations and M&A transactions are eliminated from refund eligibility under Law 48/2024/QH15, Article 15 and detailed in Decree 181/2025/ND-CP.

Since July 1, 2025, two critical requirements apply:

1. Processing timelines: Expect 6–40 working days for approval depending on risk classification
2. Threshold requirement: Accumulate at least VND 300 million (~USD 12,000) in uncredited input VAT (Law 48/2024/QH15, Article 15, Decree 181/2025/ND-CP, Articles 29, 30, 31)

Companies that maintain complete documentation typically experience faster refund processing by reducing documentation delays.

Key Takeaways

• Foreign-invested companies need a minimum of VND 300 million (~USD 12,000) in uncredited input VAT to qualify for export and investment project refunds (Law 48/2024/QH15, Article 15, Decree 181/2025/ND-CP, Articles 29, 30, 31).
• Businesses exclusively producing goods or services subject to the 5% VAT rate are eligible for refunds if uncredited input VAT reaches VND 300 million over 12 consecutive months or four quarters, starting July 1, 2025 (Decree 181/2025/ND-CP, Article 31).
• Effective January 1, 2026, supplier tax compliance verification is no longer required for VAT refund applications (Decree 359/2025/ND-CP).
• Import-for-re-export operations are eliminated from VAT refund eligibility from July 1, 2025 (Law 48/2024/QH15, Article 15 and detailed in Decree 181/2025/ND-CP). Export operations maintain 0% VAT treatment under existing regulations.
• Processing timelines range from 6 working days (for low-risk taxpayers under ‘refund first, audit later’) to 40 working days (for high-risk taxpayers under ‘audit first, refund later’), as established under Vietnam’s tax administration framework (Law on Tax Administration and implementing regulations).

Eight Categories of Eligible VAT Refunds

Vietnam’s VAT refund framework provides eight distinct refund categories serving different business situations and taxpayer types. This article focuses on export activity refunds and newly eligible 5% VAT rate businesses. For comprehensive guidance on investment project refunds, including Investment Registration Certificate requirements, separate declaration filing procedures, and common rejection triggers, see Vietnam Investment VAT Refund 2026: Compliance Guide Under New Law 48/2024.

• Exported Goods and Services: VAT refunds are available for input VAT related to the export of goods and services. The refunded VAT amount must not exceed 10% of export revenue from such goods and services, as stipulated in Circular 69/2025/TT-BTC, Article 7 and Appendix II (methodology for determining refundable VAT on exported goods and services). All compliance and documentation requirements apply.
• Investment Projects: Refunds apply to businesses during the investment phase or expansion investments. Input VAT accumulated must reach VND 300 million (~USD 12,000). Applications must be submitted within one year of project completion.
• 5% VAT Rate Business Establishments: Businesses exclusively producing goods or services subject to the 5% VAT rate can claim refunds if uncredited input VAT reaches VND 300 million (~USD 12,000) over 12 consecutive months or four quarters (Decree 181/2025/ND-CP, Article 31, effective July 1, 2025).
• Dissolution or Bankruptcy: Refunds apply upon dissolution or bankruptcy proceedings (Law 48/2024/QH15, Article 15, Clause 4). As of July 1, 2025, VAT refunds for ownership changes, enterprise type conversions, mergers, consolidations, separations, and de-mergers are eliminated—only dissolution and bankruptcy cases remain eligible.
• Refunds for Foreigners and Overseas Vietnamese: Foreign visitors and overseas Vietnamese are entitled to VAT refunds on eligible goods purchased in Vietnam. Refund claims must be filed at departure airports with original invoices and goods available for inspection.
• Projects Using ODA and Aid: Official Development Assistance (ODA) and non-refundable aid projects are eligible for VAT refunds on domestic purchases related to project activities (Decree 16/2016/ND-CP, Article 4). Grant agreements must clearly specify VAT exemption or refund provisions.
• Subjects Enjoying Diplomatic Privileges: Entities and individuals benefiting from diplomatic immunity can apply for VAT refunds on their purchases (Vienna Convention on Diplomatic Relations, Article 34). Refund procedures follow bilateral or multilateral agreements between Vietnam and the diplomat’s home country.
• Other Special Cases: Includes projects or transactions identified under special government provisions. Specific government decisions or prime ministerial directives may grant VAT refund eligibility to designated projects contributing to national development priorities.

VAT Refund Categories for Foreign-Invested Enterprises

Foreign-invested enterprises can access VAT refunds through export activities and qualifying investment projects. Both categories require uncredited input VAT (input VAT not yet offset against output VAT) to reach VND 300 million (~USD 12,000). Import-for-re-export operations and M&A transactions are excluded from refund programs. Understanding how these refund categories fit within the broader Vietnam tax system for FDI enterprises is essential for strategic tax planning.

Export Activity Refunds

Foreign-invested enterprises must accumulate uncredited input VAT of at least VND 300 million (~USD 12,000) from export operations to qualify for refunds (Decree 181/2025/ND-CP, Article 29). The refunded VAT amount must not exceed 10% of export revenue from such goods and services, as stipulated in Circular 69/2025/TT-BTC (methodology detailed in Appendix II). Export documentation requirements include VAT invoices, customs declarations, and proof of foreign payment receipt. Companies should ensure their opening business bank account in Vietnam arrangements support proper documentation of foreign payment receipts.

Investment Project Refunds

FDI companies conducting qualifying investment projects can recover input VAT exceeding VND 300 million (~USD 12,000) during the investment phase (Decree 181/2025/ND-CP, Article 30). These refunds apply to capital expenditures for equipment purchases, construction costs, and infrastructure development. The mechanism reduces immediate tax burdens during capital-intensive project phases, particularly benefiting manufacturing and industrial ventures requiring substantial upfront investments. For detailed guidance on investment project refund procedures, see VAT refund for investment projects in Vietnam.

Investment project refunds follow the same VND 300 million threshold without the 10% revenue cap applied to export refunds. Applications must be submitted within one year of project completion or commencement of operations.

New Category: 5% VAT Rate Business Establishments

Businesses exclusively producing goods or services subject to the 5% VAT rate can claim refunds if uncredited input VAT reaches VND 300 million (~USD 12,000) or more over 12 consecutive months or four quarters (Decree 181/2025/ND-CP, Article 31, effective July 1, 2025). This new category expands refund eligibility beyond export and investment project activities. Eligible businesses include certain agricultural processors, educational service providers, and healthcare facilities operating under the 5% VAT regime.

The 12-month or four-quarter accumulation period begins from the date the business commences operations under the 5% VAT rate. Businesses mixing 5% VAT rate activities with standard 10% VAT rate activities do not qualify for this refund category.

Supplier Compliance Requirements (Since January 1, 2026)

Effective January 1, 2026, Decree 359/2025/ND-CP removed the requirement that sellers must have declared and paid VAT before buyers can claim refunds. This requirement existed only briefly under Decree 181/2025/ND-CP Article 37.3 (July 1, 2025 – December 31, 2025). VAT refund applications submitted on or after January 1, 2026 no longer require supplier tax compliance verification, making compliance significantly easier for refund applicants. This change aligns with Vietnam’s broader tax incentives in Vietnam framework aimed at reducing compliance burdens for foreign investors.

Excluded Business Models Starting July 2025

Import-for-re-export operations are eliminated from VAT refund eligibility from July 1, 2025 (Law 48/2024/QH15, Article 15, Clause 1(a)). Import-for-re-export refers to importing goods into Vietnam without domestic sale or value addition, then exporting the same goods directly. These operations continue to receive 0% VAT treatment on exports but cannot claim refunds on accumulated input VAT. Companies in this sector must restructure toward domestic value-addition models (manufacturing, assembly, and quality control) to restore refund eligibility.

Mergers, acquisitions, and corporate restructuring transactions are excluded from VAT refund eligibility (Law 48/2024/QH15, Article 15, Clause 4, effective July 1, 2025). This exclusion encompasses:

• Ownership changes and equity transfers
• Enterprise-type conversions
• Mergers and consolidations
• Separations and de-mergers

Dissolution and bankruptcy cases remain eligible for VAT refunds (Law 48/2024/QH15, Article 15, Clause 4). M&A and restructuring transactions are no longer eligible for VAT refunds as of July 1, 2025 (Law 48/2024/QH15, Article 15, Clause 4). Companies planning such transactions should consult tax advisors to explore alternative structures—such as asset purchases instead of equity transfers—that may preserve refund eligibility.

Alternative Business Models for VAT Refund Eligibility

Foreign-invested enterprises affected by the import-for-re-export exclusion can restructure toward manufacturing-based activities that add value domestically. Manufacturing operations that process, assemble, or substantially transform imported inputs qualify for export refund eligibility. Equipment leasing operations where the lessor purchases equipment and leases it to third parties qualify for investment project refunds on the equipment purchase phase. Understanding Related Party Transactions under Decree 20/2025 becomes critical when structuring alternative business models involving related entities.

Direct investment in production facilities qualifies under investment project refund provisions. Service provision businesses that serve export markets (software development, business process outsourcing) maintain export refund eligibility if services are consumed outside Vietnam. Before restructuring, request a written tax ruling from your provincial Tax Department confirming the revised model qualifies for refunds under Article 29 or 30 of Decree 181/2025/ND-CP. Preemptive clarification prevents costly reclassification disputes and refund denials after capital deployment.

Processing Timelines and Risk Classification

Tax authorities classify refund applications into three risk categories that determine processing timelines. Low-risk applications are processed within 6 working days under the “Refund First, Audit Later” procedure. Standard-risk applications take 15-20 working days. High-risk applications requiring field inspection extend to 40 working days under the “Audit First, Refund Later” procedure.

Risk classification factors include:

• Tax compliance history: Companies with no tax violations in the preceding 24 months receive low-risk classification
• Audit results: Clean audit results from previous refund applications reduce risk classification
• Financial stability: Companies with stable revenue patterns and consistent profitability receive favorable classification
• Documentation completeness: Complete and accurate documentation improves risk classification

Low-risk classification typically applies to foreign-invested enterprises with established operations exceeding three years, consistent export revenue patterns, and zero tax dispute history. New operations or companies with recent tax adjustments receive standard or high-risk classification. Companies with unresolved tax disputes or pending audits automatically receive high-risk classification requiring the 40-day processing timeline. Maintaining proper accounting services vietnam standards helps demonstrate financial stability and documentation completeness to tax authorities.

Documentation Requirements for Refund Applications

VAT invoices must include complete supplier information: tax identification number, business address, invoice serial number, and itemized goods or services descriptions (Circular 32/2025/TT-BTC, Article 10, effective June 1, 2025). Electronic invoices must bear valid digital signatures from the issuing supplier. Paper invoices require original copies for inspection purposes, though electronic submission through the national tax portal is mandatory.

Export documentation includes customs declarations (forms 03/HQXK for export goods), proof of foreign payment receipt through licensed commercial banks, and shipping documents (bills of lading, airway bills) confirming goods departure from Vietnam. For services exports, documentation includes service contracts, proof of service delivery to foreign clients, and bank transfer confirmations showing payment from overseas. Understanding audit requirement in vietnam standards helps ensure documentation meets regulatory expectations.

Investment project documentation requires Investment Registration Certificate (IRC) or Investment Policy Decision, construction permits for facility development projects, equipment purchase invoices with customs import declarations, project completion certificates or partial completion confirmations, and financial statements demonstrating project expenditure allocation. For detailed investment project refund documentation and procedures, see Vietnam Investment VAT Refund 2026.

Financial statements must reconcile uncredited input VAT balances to accounting records. The VAT declaration form 02/GTGT must show cumulative uncredited input VAT reaching the VND 300 million threshold.

Submission Procedures Through the National Tax Portal

Refund applications are submitted electronically through the General Department of Taxation’s national portal at https://thuedientu.gdt.gov.vn. Foreign-invested enterprises require a valid digital signature certificate issued by approved certification authorities (VNPT-CA, FPT-CA, Viettel-CA, or BKAV-CA) to access the portal. Company legal representatives or authorized tax agents can submit applications with appropriate power of attorney documentation.

The submission process follows these steps:

1. Log in to the national tax portal using digital signature credentials
2. Select “VAT Refund Application” from the tax declaration menu
3. Complete form 01/ĐNHT (VAT refund application form) with refund category selection
4. Upload supporting documents: invoices, export documentation
5. Submit application and receive automatic acknowledgment number

Tax authorities issue acknowledgment within 2 working days of electronic submission. The acknowledgment confirms application receipt and initiates the processing timeline. Incomplete applications receive rejection notices within 5 working days specifying missing documentation requirements. Corrected applications must be resubmitted within 30 days to maintain the original application date for threshold calculation purposes. For enterprises managing cross-border payments, understanding profit repatriation Vietnam procedures ensures proper handling of refund proceeds.

Preparation Recommendations for FDI Companies

Review current documentation systems to ensure VAT invoices, export documentation, and financial statements meet regulatory requirements. Consider restructuring operations if currently operating import-for-re-export or planning M&A activities that would eliminate refund eligibility.

For foreign-invested enterprises requiring detailed compliance guidance, consultation with qualified tax advisors ensures applications meet all regulatory requirements under Vietnam’s revised VAT refund framework.

Legal Disclaimer: This article provides general information about Vietnam’s VAT refund regulations. Foreign-invested enterprises should consult qualified tax advisors and legal counsel for specific compliance guidance applicable to their operations.