A VAT refund pays back, in cash, input VAT you cannot offset against output VAT. Deduction-method businesses can claim once uncredited input VAT reaches VND 300 million, through three channels: export, a new investment project, or 5% goods. The tax authority resolves a clearance dossier within 6 working days of the acceptance notice, and an audit dossier within 10 working days of the inspection conclusion.
Timely recovery of accumulated input VAT lowers debt financing costs and keeps liquidity steady through manufacturing cycles. Here is how the main “tax refund” types differ, so you land on the right one:
- VAT refund for businesses: the subject of this guide.
- VAT refund for foreign visitors leaving Vietnam: a separate scheme for individuals, outside this guide.
- Personal income tax refund: handled through PIT finalization, outside this guide.
- Import-export duty refund on re-exported goods: handled by customs, outside this guide.
The statutory framework governing VAT refunds in Vietnam is established by two principal legislative instruments:
- Substantive refund standards: Defined under Article 15 of the Law on Value-Added Tax No. 48/2024/QH15 (effective July 1, 2025), establishing a uniform quantitative threshold of VND 300 million and standardizing statutory exclusions. For foundational rules, consult our guide on VAT compliance in Vietnam.
- Procedural administration: Governed by the Law on Tax Administration No. 108/2025/QH15, Decree No. 252/2026/ND-CP, and Circular No. 89/2026/TT-BTC (replacing Circular No. 80/2021/TT-BTC effective July 1, 2026). Applications are processed through two procedural streams: 06 working days for pre-refund clearance and 10 working days from the on-site audit conclusion for pre-refund audits.
Tax authorities screen refund dossiers against electronic invoice data. Lacking non-cash payment documentation leads to the affected input VAT being denied deduction and refund; a dossier moves to the pre-refund audit stream only in the cases listed below.
Statutory VAT refund framework under Law 48/2024/QH15
VAT refunds in Vietnam do not apply automatically to all uncredited input VAT balances. The state reserves cash refunds strictly for economic activities generating strategic value, prioritizing international exports and long-term capital investments.
Article 15 of Law No. 48/2024/QH15 establishes a core threshold requirement: business establishments employing the deduction method are eligible for VAT refunds only when accumulated uncredited input VAT reaches at least VND 300 million.
Tax authorities utilize automated electronic invoice data reconciliation. They screen refund dossiers against e-invoice and tax-return data through the tax information system and may request explanations and supporting documents. Since January 1, 2026, Law 149/2025/QH15 no longer makes the seller’s declaration and payment of VAT a refund condition.
Three core refund channels for foreign-invested enterprises
FDI enterprises operating in Vietnam recover liquidity primarily through three commercial refund channels:
| Refund channel | Qualifying entity | Minimum threshold | Maximum refund cap |
|---|---|---|---|
| Exported goods and services | Export manufacturing and toll processors | VND 300M per month or quarter | Maximum 10% of export revenue in period |
| New investment projects | Projects in pre-operational construction phase | VND 300M cumulative on Form 02/GTGT | Total qualifying input VAT of investment |
| 5% VAT rate businesses | Producers of 5% goods and services (input VAT of other rates excluded) | VND 300M over 12 months or 4 quarters | Total uncredited input VAT balance (after offsetting VAT payable, at least VND 300M remaining) |
Outside these three commercial mechanisms, the law also provides refunds for specialized situations: dissolution or bankruptcy, non-refundable official development assistance (ODA) and aid, persons entitled to diplomatic immunity, foreigners carrying goods abroad, and cases under international treaties or decisions of competent authorities.
Channel 1: VAT refunds for exported goods and services
Export revenues qualify for a 0% VAT rate, entitling manufacturers to claim input VAT incurred on production materials and auxiliary services.
Deduction criteria and the VND 300 million threshold
Under the VAT Law, business establishments filing monthly or quarterly tax returns qualify for VAT refunds if accumulated uncredited input VAT on export operations reaches at least VND 300 million.
Prior to compiling a refund dossier, enterprises must offset input VAT generated by export activities against output VAT payable on domestic sales within the same tax period using Form 01/GTGT. Only remaining uncredited input VAT of at least VND 300 million qualifies for cash refund consideration.
Regulatory 10% export revenue cap mechanism
The VAT Law sets a statutory ceiling on export refunds. The total refundable VAT amount cannot exceed 10% of export revenue of the refund period:
When qualifying input VAT exceeds the 10% revenue ceiling, the surplus amount is not forfeited. The enterprise carries the remaining credit forward to subsequent tax periods for future deduction or refund claims. Enterprises that both export and sell domestically must account separately for input VAT on export goods; where it cannot be separated, it is allocated by the ratio of export revenue to total taxable revenue of the refund period (Article 29 of Decree 181). For software and offshore outsourcing operations, review our analysis on export services VAT; export processing enterprises follow the EPE VAT regime. If you want a specialist to prepare the export refund dossier, see our VAT refund service.
Statutory exclusion of imported goods subsequently exported
The VAT Law provides that refunds do not apply to goods imported and subsequently exported.
Under Decree 181/2025/ND-CP, this means goods a business imports and then exports directly or through an entrusted exporter, and it does not include materials imported to manufacture or process export goods.
Operational guidance: Multinationals transshipping goods through Vietnamese territory must distinguish between importing goods for export as they are (ineligible for refunds) and processing or assembly manufacturing before export (eligible for export refunds when the conditions are met).
Channel 2: VAT refunds for new investment projects during pre-operation
FDI enterprises incur substantial input VAT on land leases, civil factory construction, and machinery procurement prior to revenue generation. The investment project refund channel recovers capital expenditure before commercial operation.
Legal prerequisites and separate Form 02/GTGT filing
The VAT Law provides that new investment projects in the pre-operational construction phase qualify for VAT refunds once cumulative input VAT hits VND 300 million.
The project must meet these criteria:
- Possess a valid Investment Registration Certificate (IRC) or competent authority approval.
- Have contributed the full charter capital registered at the time of filing the refund application (Article 30 of Decree 181/2025/ND-CP), with proof of contribution in the dossier.
- File dedicated project VAT returns using Form 02/GTGT, segregated from corporate operating accounts.
- File while the project is in the investment stage, or within 1 year of the project or phase completion date (the date it generates revenue) if not yet refunded.
For procedural details, see our technical analysis on investment project VAT refunds.
Offsetting rules with concurrent operating activities
When an existing operational business establishes an additional investment project:
- Input VAT reported on Form 02/GTGT must first offset output VAT payable from existing operational business on Form 01/GTGT.
- If remaining uncredited input VAT on the project reaches at least VND 300 million after corporate offsetting, the enterprise qualifies for cash refund.
- Expansion investment projects are also refundable when they form fixed assets and meet the conditions above.
Channel 3: VAT refunds for businesses subject to the 5% tax rate
The VAT Law resolves a long-standing cash trap for capital-intensive manufacturers facing structurally unbalanced tax rates.
Continuous 12-month or 4-quarter accumulation criteria
Enterprises in agricultural processing, fertilizer production, medical equipment, and cultural supplies frequently experience input VAT taxed at the standard 10% rate while output sales are taxed at 5%. This structural imbalance creates chronic input tax accumulation.
The statute allows establishments producing goods or services taxed at 5% to claim refunds when uncredited input VAT reaches VND 300 million over 12 consecutive months or 4 consecutive quarters. The input VAT counted is that incurred from July 1, 2025 (Article 39 of Decree 181).
Exposure to mixed revenue streams
The VAT Law builds this refund channel around producers of 5% goods and services, and Decree 181 also covers businesses that have other tax rates.
If an enterprise generates mixed revenue streams (selling 5% agricultural goods while providing auxiliary commercial services taxed at 10%), only the input VAT attributable to the 5% production activity is considered under this channel. The business must account for it separately, or allocate shared input VAT by the share of 5% production revenue in total taxable revenue. The remaining uncredited input VAT stays in the general pool for standard credit carry-forward.
Risk-based refund application classification and timelines
Under the Law on Tax Administration, Decree 252/2026/ND-CP, and Circular 89 (replacing Circular 80/2021/TT-BTC effective July 1, 2026), dossiers assessed as high risk are subject to pre-refund audit.
Within 03 working days of receiving a refund application, the tax authority issues a notice accepting or rejecting the dossier (Article 31 of the Decree).
Pre-refund clearance stream within 6 working days
Applicable to refund dossiers that do not fall within the pre-refund audit cases listed below:
- Statutory timeline: No later than 06 working days from issuance of the formal dossier acceptance notice, excluding explanation and supplementation time.
Tax authorities conduct post-refund audits within 5 years from the date of the refund decision, based on risk management principles (Article 22 of the Law on Tax Administration).
Pre-refund audit stream under new statutory benchmarks
Applicable to scenarios requiring on-site audit of accounting records and facilities before cash disbursement:
-
Statutory timeline: No later than 10 working days from issuance of the on-site inspection conclusion or sanction decision by the tax authority, excluding explanation and supplementation time.
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Pre-refund audit cases (Article 30 of the Decree):
- First-time refund dossiers for each investment project or each refund case.
- Dossiers filed within 2 years of the taxpayer being penalized for tax evasion.
- Dossiers, or part of the refund amount, assessed as high risk in tax management.
- Dossiers of enterprises and organizations upon dissolution or bankruptcy.
Refunds of import and export duties handled by customs follow their own pre-refund check cases under the same Decree; VAT refund dossiers filed with the tax authority follow the cases above.
Standard statutory refund documentation under Circular 89/2026/TT-BTC
Effective July 1, 2026, Circular 89/2026/TT-BTC modernizes tax administration by integrating refund requests for export, investment-project and 5% refunds directly into VAT returns 01/GTGT and 02/GTGT, replacing Forms 01/HT and 01-1/HT of prior Circular 80 for those cases (Form 01/HT is still used for ODA and non-refundable aid refunds):
- Integrated electronic VAT declaration:
- Export operations and 5% goods: Declare refund indices directly on VAT Declaration Form No. 01/GTGT.
- New investment projects: Declare on VAT Declaration for Investment Projects Form No. 02/GTGT.
- Statutory refund schedule (Appendix Form No. 01-8/GTGT): Refund-request information annex, attached to Form 01/GTGT or 02/GTGT and submitted concurrently via the eTax portal.
- Non-cash payment verification records (a deduction condition, not on the Article 46 list): Required for purchase transactions of VND 5 million or higher. Review our guide on non-cash payment rules from 5 million VND.
- Foreign trade contracts and customs declarations (a deduction condition for exported goods, not on the Article 46 list): Needed for deduction.
- Investment project dossier (for Form 02/GTGT, filed the first time or when changed): Copy of the IRC or equivalent document; for projects with construction works, land documents or a land lease agreement plus a construction permit where one is required; proof of charter capital contribution.
Transitional rules: Returns for tax periods before July 1, 2026 use the earlier forms. Refund dossiers already accepted but not yet resolved before that date continue under the earlier procedure. Refund requests sent after the electronic-transaction roadmap date use Appendix 01-8/GTGT (Article 100 of the Circular).
Summary and compliance recommendations for FDI investors
VAT refund compliance requires invoices and bank cash flows that match. Conducting preemptive vendor audits and standardizing non-cash payment records from the outset safeguards working capital liquidity.
Contact our Certified CPAs and tax compliance team to prepare your refund dossier through our VAT refund service. Our audit support services cover the inspection side.
