Electronic invoices are a necessary step towards transparency in business operations and combating tax evasion. According to regulations, for the sale of goods, the time of invoice issuance is when the ownership or right to use the goods is transferred to the buyer, regardless of whether payment has been received or not.
However, in practice, many transactions can still result in order cancellations, returns, or unsuccessful deliveries. Therefore, in the draft Circular on electronic invoices of the Ministry of Finance , many businesses and business households have suggested that regulations on the timing of invoice issuance should be more flexible, tailored to each industry.
For Ms. Tran Nguyen Anh Ngoc's business, creating electronic invoices for each small transaction is still a challenging task. The unique characteristic of retail is that customers can change their minds after payment or make adjustments right at the counter.
"For example, when a customer buys goods, pays, and gets a bill, it means the invoice has been issued. But if they change their mind or order something else, we have to cancel the invoice and create a new one. I'm not sure if canceling an invoice like that counts as revenue. Do I need to explain why I had to cancel it?" wondered Ms. Tran Nguyen Anh Ngoc, owner of Hino House business in Ho Chi Minh City.
For businesses and individual entrepreneurs in e-commerce, thousands of orders can be generated daily, but not all are completed. Depending on the industry and peak season, the rate of canceled, returned, or exchanged orders can range from 10% to 30% of the total number of orders sent.
If the invoice is issued from the outset, the business will have to go through many additional steps to adjust, replace, or cancel the invoice.
"Our recommendation is that invoicing should reflect the actual status of the order, upon successful delivery, or after the return/exchange period stipulated by the platform. This way, businesses can still comply correctly, but without operational bottlenecks or incurring unnecessary compliance costs," said Mr. Vu Viet Duc, Deputy General Director of DATHACO Company.
According to experts, the principle of invoicing when transferring ownership is necessary for revenue management and preventing tax evasion. However, in modern retail models, the concept of "transfer" is not always straightforward. If only a rigid timeframe is applied, businesses can easily fall into a situation where they are correct in terms of operational procedures but encounter difficulties with invoicing procedures.
Mr. Tran Xoa, Director of Minh Dang Quang Law Firm, stated: "When is it considered a transfer of ownership? The Ministry of Finance must clarify each case. Each case must be regulated in a specific way, because currently, it only states 'transfer of ownership, issue an invoice.' We need to clarify this to avoid people being unfairly penalized."
Many suggest that the timing of invoicing should be more closely aligned with the transaction status. For e-commerce, this could be the time of successful delivery or after the return period stipulated by the platform has ended. For brick-and-mortar retail, revenue could be aggregated to issue invoices at the end of the day, end of the week, or on a more appropriate basis.
Source: https://vtv.vn/can-thao-go-vuong-mac-quy-dinh-thoi-diem-xuat-hoa-don-10026052711335854.htm







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