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  • Latest update on VAT refund in 2025 – Businesses need to know now

    VAT refund is an important step to help businesses recover input tax paid, optimize cash flow and ensure compliance with legal regulations. According to current regulations, businesses are eligible for VAT refund when:

    • Have export goods and services
    • New investment project
    • Input tax is greater than output tax.

    VAT refunds play a key role in helping businesses optimize cash flow, increase transparency and encourage export activities. The following article will focus on analyzing the conditions, procedures and processing time of VAT refund dossiers according to the latest regulations in 2025.

    What is VAT refund?

    VAT refund is the act of the tax authority returning to organizations and individuals the VAT amount that has been overpaid or not deducted during the production and business process. Simply put, this is a mechanism to refund the input tax that businesses have paid when purchasing goods and services for legal business activities.

    The purpose of VAT refund is to ensure tax fairness, avoid double collection, and at the same time support cash flow for businesses, especially export and new investment businesses in the stage of expanding production and business.

    Cases eligible for VAT refund

    According to the provisions of the Law on VAT (amended and supplemented) and Decree 181/2025/ND-CP and guiding circulars, enterprises are entitled to VAT refunds in the following main cases:

    Board: Cases eligible for VAT refund 

    Case Content
    VAT refund for exports Business establishments that export goods and services in a month or quarter and have input value-added tax of 300 million VND or more that has not been fully deducted will be refunded value-added tax on a monthly or quarterly basis, except in the case of imported goods that are then exported to another country.
    VAT refund for investment Business establishments paying VAT according to the deduction method, if they have a new investment project or expansion project according to the provisions of the law on investment, are in the investment phase and incur input VAT that has not been refunded, they are allowed to offset it with the VAT payable from current production and business activities (if any). After offsetting, if the remaining input VAT of the project is 300 million VND or more, the enterprise will be refunded VAT according to regulations.
    VAT refund for goods and services subject to VAT rate 5% Business establishments that only produce goods and provide services subject to VAT rate 5%, if they have input VAT that has not been fully deducted from 300 million VND or more after 12 consecutive months or 04 consecutive quarters, will be refunded VAT.
    VAT refund for dissolved or bankrupt businesses Enterprises paying VAT according to the deduction method are entitled to a tax refund upon dissolution or bankruptcy if there is excess VAT paid or input VAT that has not been fully deducted.

    In case a cooperative group is converted into a cooperative, the new unit is entitled to inherit the excess or undeducted VAT amount to continue deducting or requesting a tax refund according to regulations.

    VAT refund for goods purchased in Vietnam and brought with you when leaving the country Foreigners and Vietnamese people residing abroad (excluding flight crew and seafarers) with passports or international travel documents are entitled to tax refunds for goods purchased in Vietnam and brought with them when leaving the country.
    VAT refund for programs using ODA capital and humanitarian aid Programs and projects using non-refundable ODA capital or humanitarian aid are entitled to a refund of VAT paid when purchasing goods and services in Vietnam to serve those programs and projects.
    VAT refund for cases of diplomatic privileges and exemptions Those who enjoy diplomatic privileges and immunities when purchasing goods and services in Vietnam will be refunded the VAT paid, based on the invoice or payment document showing VAT.
    VAT refund according to international treaties Business establishments are entitled to VAT refunds upon decision by competent authorities or according to international treaties to which Vietnam is a party.

    Thus, VAT refunds are applied to many different cases depending on the nature of the business or organization's activities and subjects. Understanding the regulations for each type of tax refund helps businesses proactively prepare documents, avoid errors and shorten processing time from the tax authorities.

    Cases where VAT is not refunded

    According to Clause 3, Article 30 Decree 181/2025/ND-CP, there are 4 cases where enterprises are not entitled to VAT refund, but must transfer the undeducted tax amount of the investment project to the next period, specifically as follows:

    • The investment project of the business establishment has not yet contributed enough registered charter capital at the time of submitting the tax refund application.
    • Investment projects of business establishments in conditional industries and professions will be considered when they do not fully satisfy the business conditions according to the law on investment, except for the cases specified in Clause 2 of this Article.
    • Investment projects of conditional business establishments are not entitled to VAT refunds if, during the course of operation, the business establishment has its license, certificate or approval document related to the conditional business or industry revoked, or does not meet the investment and business conditions as prescribed by law. The time of non-refund of VAT is calculated from the time the documents are revoked or when the competent state agency discovers that the business establishment does not meet the investment conditions.
    • Projects on exploitation of resources and minerals (excluding exploration, prospecting and development of oil and gas mines) and projects on production of processed resources and minerals into other products according to Clause 14, Article 4 of this Decree.

    Conditions for VAT refund 

    Pursuant to Article 37 of Decree 181/2025/ND-CP, business establishments and organizations subject to VAT refund under Articles 29 - 32 of Decree 181/2025/ND-CP will be refunded if they meet the following conditions:

    Điều kiện hoàn thuế GTGT doanh nghiệp cần biết
    Conditions for VAT refund that businesses need to know
    • Must be a business that pays tax using the tax deduction method.
    • Establish and keep accounting books and accounting documents according to the provisions of law
    • Comply with regulations on input VAT deduction
    • At the time of filing the application, the business is eligible for a VAT refund, has input tax that fully meets the conditions for a refund, and complies with tax declaration regulations. The business prepares a VAT refund application for each case and sends it to the competent tax authority. The tax authority will classify the application into pre-refund or pre-refund inspection, and then resolve it according to the provisions of the law on tax administration.

    The seller has declared and paid VAT according to regulations for invoices issued to the business establishment requesting a tax refund, determined as follows:

    • At the time of submitting the tax refund application, the seller has fully declared and paid VAT for the corresponding period, and has no tax debt related to the tax refund period requested by the business establishment.
    • At the time of receiving the tax refund dossier, the tax authority will rely on the processing results of the automatic information technology system to determine whether the seller has declared and paid VAT according to regulations.
    • If the seller has not fully submitted the VAT declaration dossier for the corresponding tax period (even if it is not yet due) or still owes VAT, the business establishment will not be entitled to a tax refund for invoices related to that tax period.

    Once all conditions for VAT refund have been met, businesses need to grasp the tax refund time to forecast cash flow and ensure benefits are exercised on time.

    VAT refund time

    According to Article 75 Law on Tax Administration 2019 Regulations on the time limit for processing tax refund applications are as follows:

    Thời gian hoàn thuế GTGT doanh nghiệp cần chú ý
    VAT refund time businesses need to pay attention to

    For files subject to pre-refund and post-inspection

    After submitting the tax refund dossier to the tax authority, if the tax refund dossier does not fall under the subject and case of refund or does not contain enough information for the tax authority to determine, the tax authority shall send a notice to the taxpayer within 03 working days from the date of receiving the complete tax refund dossier.

    If the tax refund dossier meets the conditions for tax refund, the tax authority shall issue a tax refund decision within no more than 06 working days from the date of receipt of the complete tax refund dossier.

    For files subject to pre-inspection, post-refund

    The tax authority shall conduct an inspection at the taxpayer's headquarters and issue a tax refund decision within no more than 40 days from the date of receipt of a complete tax refund dossier.

    Latest detailed VAT refund process 2025

    Currently, the VAT refund procedure is carried out entirely online (Electronic Information Portal), helping businesses save time and making the receiving process transparent. To help businesses easily understand and comply with regulations, below are the detailed steps in the VAT refund process:

    Quy trình hoàn thuế GTGT chi tiết cho doanh nghiệp năm 2025
    Detailed VAT refund process for businesses in 2025

    Step 1: Identify the subject and prepare complete and correct documents

    Enterprises are subject to VAT refund according to Decree 181/2025/ND-CP (mentioned above). Depending on the type of tax refund, the dossier will include:

    • VAT declaration for the period in which the refund request is made
    • List of invoices and vouchers for purchased goods and services
    • Export contract and customs declaration (if tax refund for exported goods)
    • Non-cash payment documents (payment orders, bank statements, etc.)
    • Explain the production and business situation if requested

    Step 2: Submit application 

    Enterprises submit tax refund applications through the General Department of Taxation's electronic information portal at the address: https://thuedientu.gdt.gov.vn.

    Here, taxpayers log in with the account registered with the tax authority, select "Electronic tax refund", upload documents and sign confirmation with a digital signature.

    Step 3: Tax authorities receive and respond to application information

    Within 3 working days from receiving the tax refund dossier, the tax authority will classify and notify the taxpayer in one of the following two cases:

    • Accepted application: The tax authority will notify the taxpayer of the deadline for processing the tax refund.
    • Incomplete application: The tax authority will notify the enterprise in writing, requesting it to explain or supplement the application. The time for the enterprise to explain will not be counted in the time limit for processing the tax refund application.

    Step 4: Receive your tax refund

    Taxpayers receive tax refunds according to the notice of the tax authority. Specifically, the time to receive tax refunds is as follows:

    • No later than 06 working days: For files subject to pre-tax refund
    • No later than 40 working days: For files subject to pre-refund inspection.

    Despite having a good understanding of the VAT refund process, many businesses still encounter common errors that cause their applications to be delayed or rejected. Below are some common errors and how to avoid them.

    Common mistakes in VAT refund procedures

    Below are common mistakes in VAT refund procedures that businesses should pay attention to:

    About tax refund procedures 

    During the VAT refund process, businesses often encounter some common errors. Below are detailed errors that need to be noted to avoid rejection of the application or prolonging the processing time:

    • Incomplete records according to regulations Circular 80/2021/TT-BTC
    • Declaring and supplementing tax declaration documents not in accordance with regulations
    • Allocating VAT refunds for exported goods and services not in accordance with regulations.
    • Request for tax refund exceeding 10% revenue.

    In addition to common errors in tax refund procedures, businesses also need to pay attention to common errors in the post-audit stage, because this is an important step that directly affects the processing of VAT refund dossiers.

    Errors in the post-audit process

    When conducting post-audit, VAT refund dossiers may encounter many common errors. Specifically, the errors are listed as follows:

    • Input VAT of goods and services not serving production and business activities.
    • Deduct input VAT from incorrect invoices or incorrect tax period.
    • Supplement tax declaration after tax authority makes tax settlement decision.
    • Transfer VAT declaration from goods and services serving production and business (form 01/GTGT) to goods and services serving investment projects (form 02/GTGT) and vice versa.
    • Illegal documents and invoices.
    • There is no non-cash payment document for purchased goods and services as prescribed for tax deduction.
    • Exported goods and services do not have bank payment documents, so they are not eligible for tax deduction or refund.

    Recognizing and avoiding common errors in VAT refund dossiers will help businesses shorten processing time, ensure legal rights and reduce the risk of rejection. Preparing complete and accurate dossiers from the beginning is an important step for a quick and effective tax refund.

    Conclude

    VAT refund is an important benefit for businesses, but to have the documents approved quickly and on time, it is necessary to understand the conditions, procedures and common errors. Let the team of experts at MAN - Master Accountant Network accompany and support businesses in preparing accurate tax refund documents, saving time and ensuring legal safety.

    Contact information MAN – Master Accountant Network

    • Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
    • Mobile / Zalo: 0903 963 163
    • E-mail: man@man.net.vn

    Editor MAN – Master Accountant Network

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    Le Hoang Tuyen

    FOUNDER-MAN

    Hello! I am Le Hoang Tuyen, Founder of MAN – Master Accountant Network. With many years of experience, our company provides professional services in the fields of Auditing, Accounting, Tax Reporting, Transfer Pricing Reporting… In addition, I also spend a lot of time and passion to share my extensive professional knowledge. See details about me here.

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