In accounting and tax practice, handling sales bonuses and incentives for dealers remains a point of concern for businesses, especially the question of whether or not a value-added tax invoice must be issued. Based on current regulations in Decree 181/2025/ND-CP, the following content will clearly analyze the tax nature of sales bonuses to help businesses apply the correct regulations and minimize risks.
Revenue not related to the sale of goods or provision of services.
According to point b, clause 1, Article 14 of Decree 181/2025/ND-CP, the VAT taxable value only includes revenue directly arising from the sale of goods or provision of services. Revenue not directly related to these two activities will not be included in the VAT calculation basis.
Based on point b, clause 1, Article 14 of Decree 181/2025/ND-CP, it is stipulated that:
“This excludes income unrelated to the sale of goods or provision of services by the business: income from monetary compensation (including compensation for land and assets on land when land is expropriated by a decision of a competent state agency), bonuses, third-party claims from insurance activities, collection fees, fees from state agencies for performing collection and disbursement activities on behalf of state agencies, and financial income.
This regulation is an important basis for determining tax obligations for subsidies and bonuses received in addition to the selling price.
The nature of output-based support
Suppose company A pays agent B 5,000,000 VND when the agent achieves a sales volume of 500kg and fulfills its payment obligations according to the contract. In this case, the payment is made after the commitment conditions are met, so it should be considered a conditional bonus, not incurred simultaneously with each specific sales transaction.
This support is typically intended to offset operating costs, asset depreciation, or maintain brand image during the partnership. Since it does not reduce the unit price of each issued sales invoice, this amount is not considered a trade discount but is recorded as other financial income for the recipient.
Is it necessary to issue a VAT invoice for sales bonuses?
Based on legal regulations and the consistent interpretation in practice:
Sales bonuses are not subject to VAT invoicing because:
- Not arising from the provision of goods or services at the time of payment;
- Do not change the selling price already stated on the invoice;
- It does not constitute revenue subject to VAT.
Therefore, the party paying the bonus is not required to issue a VAT invoice for this amount.
Requirements for Accounting and Tax Documents
Even without issuing VAT invoices, businesses still need to ensure they have complete documentation to facilitate tax audits and inspections. Specifically:
- The party paying the bonus should prepare a payment voucher or payment order.
- Recipient of the reward: prepare a receipt as per regulations.
- The accompanying archived documents include: Economic contracts, notices or regulations on reward/support programs, and minutes confirming sales volume or reward eligibility conditions.
Distinguish between sales bonuses and trade discounts.
Confusing these two concepts is a common cause of errors in tax filing. They can be distinguished as follows:
| Criteria | Trade discount | Sales bonus |
| Nature | Bulk purchase discount | Bonus payment upon fulfilling commitment requirements. |
| Time of application | When selling goods or at the end of the billing period. | After the business period ends. |
| Bill | The invoice must be created or adjusted. | No VAT invoice issued. |
| VAT | Reduce the taxable value. | No impact on the tax base. |
| Document | Invoices and payment documents | Receipts and payment vouchers, and accompanying documents. |
Understanding and correctly applying the regulations in Decree 181/2025/ND-CP will help businesses properly handle sales bonuses, thereby optimizing accounting processes, minimizing risks related to invoices and documents, and avoiding unnecessary disputes with tax authorities.
Contact information MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
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- Email: man@man.net.vn
Content production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Source:
- Decree 181/2025/ND-CP provides guidance on the Value Added Tax Law.
- Article Vietnam Law
