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Regarding the timing of VAT invoice issuance for exported goods, the lack of unified guidance in the past has led to differences in the viewpoints of tax authorities concerning the timing of invoice issuance and the recognition of export revenue.
However, at the Taxpayer Dialogue Conference held in five southern provinces and cities in 2024, organized by the General Department of Taxation on September 24, 2024, the tax authority has clarified this issue. Accordingly, pursuant to point c, clause 3, article 13 of Decree No. 123/2020/ND-CP dated October 19, 2020, of the Government on invoices and documents, enterprises applying the credit-invoice method for VAT declaration must issue electronic VAT invoices for exported goods only after completing customs procedures for the exported goods. Prior to this, during the transportation of goods to border gates or export clearance locations, enterprises shall use the Internal Delivery cum Transportation Note as supporting documents for the circulation of goods in the market.
Furthermore, pursuant to clause 4, article 16 of Circular No. 219/2013/TT-BTC (as amended and supplemented by clause 7, article 3 of Circular No. 119/2014/TT-BTC):
“The date to determine revenue from export to calculate tax is the day on which customs procedure completion is confirmed on the customs declaration.”
Clause 21, article 4 of the Customs Law No. 54/2014/QH13 dated June 23, 2014, defines the completion of customs procedure for goods to be exported as "customs clearance":
“Customs clearance means the completion of customs formalities for goods to be imported, exported or placed under another professional customs management mechanism.”
Based on the above guidance and regulations, the timing of VAT invoice issuance for exported goods, which also serves as the point of revenue recognition for tax calculation purposes, is determined as the date of customs procedure completion, i.e., the date of customs clearance.