Handling discounts incurred in 2025 but invoiced in early 2026 often causes confusion for accounting departments. To resolve this issue, the Quang Ninh Provincial Tax Department has issued regulations. Official Document 802/QNI-QLDN1 Regarding trade discounts as of March 5, 2026, this is an important legal document that helps businesses standardize the process of issuing electronic invoices, optimize corporate income tax costs, and accurately reflect their financial picture.
Principles for creating discount invoices according to Official Letter 802/QNI-QLDN1
In business, discount policies aimed at boosting sales are very common. However, for these discounts to be considered legitimate expenses, businesses need to comply with regulations regarding invoice formats.
Showing the content on the invoice
According to the regulations at Decree 123/2020/ND-CP (Article 10, Clause 6, Point d), when applying trade discounts, this must be clearly stated on the invoice. The VAT taxable price is the price after deducting the agreed-upon discount. This ensures that the business only fulfills its tax obligations on the actual revenue received.
Adjustment invoicing method
Based on the guidance of Official Letter 802/QNI-QLDN1 on trade discounts and amendments at Decree 70/2025/ND-CPThe invoicing process is divided into the following scenarios:
- Purchase-by-purchase discount: The discount amount is deducted directly from the invoice for that particular order.
- Sales/Quantity Discount: The discount amount will be adjusted on the invoice for the last purchase or the next period.
- Create a separate adjustment invoice: If the discount amount is greater than the value of the goods on the final invoice, the business must create a separate adjustment invoice along with a detailed list of previous invoices for comparison.
Accounting and revenue period determination
One of the key points of Circular 802/QNI-QLDN1 regarding trade discounts is clarifying the timing of revenue deduction recognition between 2025 and 2026. This applies to units currently using such discounts. full accounting serviceThe synchronization of this data will be handled meticulously by experts to avoid errors during the final settlement process.
For businesses applying Circular 200/2014/TT-BTC
The deduction is tracked through account 521. The accounting year is determined based on the date of issuance of the Financial Statements:
- Before issuing the 2025 financial statements: If the discount for goods sold in 2025 is determined before closing the books and issuing the financial statements, the accountant will record a reduction in revenue in 2025 (Adjustment event after the end of the accounting period).
- After the 2025 financial statements are released: If the invoice is issued after the 2025 financial statements have been submitted, this deduction will be accounted for in the business results of 2026.
For businesses applying Circular 133/2016/TT-BTC
Small and medium-sized enterprises (SMEs) directly account for transactions in account 511. However, the principle of timing based on the issuance of financial statements remains consistent and appropriate to ensure uniformity.
Corporate income tax policy and deduction conditions under the new law.
To ensure that the discount granted under Official Letter 802/QNI-QLDN1 regarding trade discounts is not disallowed by the tax authorities during tax settlement, businesses need to pay attention to the regulations in the Corporate Income Tax Law No. 67/2025/QH15.
Taxable revenue for corporate income tax
Revenue is the total amount of money from the sale of goods and services (including surcharges and additional fees). The method of determination depends on the VAT calculation method:
| Tax calculation method | Basis for determining revenue | Notes on VAT |
| Deduction method | The selling price excludes VAT. | Excluding VAT |
| Direct method | Total payment amount | Including VAT |
Through the comparison table above, businesses can see the significant differences in determining revenue value as the basis for calculating corporate income tax. Businesses can also seek further advice from relevant providers. tax accounting services To accurately classify the method right from the declaration stage, avoid discrepancies in the amount of tax payable.
03 Conditions for the discount to be deducted
According to Article 9 of the Corporate Income Tax Law 2025, for trade discounts to be recognized as reasonable expenses and deductible when determining taxable income, businesses must ensure they meet the following qualitative and quantitative standards:
- These issues arise from actual circumstances and are directly related to the unit's production and business operations.
- All necessary legal invoices and documents are available (economic contract, detailed statement, adjustment invoice).
- Non-cash payment documents are required for invoices valued at 20 million VND or more.
VAT declaration for adjustment invoices
The declaration of trade discounts as per Official Letter 802/QNI-QLDN1 requires close coordination between the seller and the buyer to avoid data discrepancies in the electronic invoicing system.
- Seller: Declare a reduction in output tax in the period when the adjusted invoice is issued (year 2026).
- Buyer: Declare the corresponding reduction in input tax in the period in which the adjusted invoice is received.
Advice for accountants when implementing Official Letter 802/QNI-QLDN1
To effectively manage tax risks, businesses should take the following steps:
- Establish regulations: Issue specific discount policies in economic contracts or financial regulations at the beginning of the year.
- Complete the documentation: Always have a detailed list of invoices along with the adjusted invoices ready for future explanations.
- Time control: Review and approve discounts for 2025 before issuing financial statements to ensure they are recognized as deductions in the correct period, optimizing the corporate income tax obligations of the previous year.
Understanding Circular 802/QNI-QLDN1 on trade discounts will help businesses be more confident during tax audits and inspections, while also ensuring the legitimate rights of the unit in implementing customer incentive policies.
Source:
- Corporate Income Tax Law 2025
- Decree 70/2025/ND-CP
- Decree 123/2020/ND-CP.
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Content production by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant NetworkCPA Vietnam auditors with over 30 years of experience in accounting, auditing, and financial consulting.
