Official Document 2398/CT-CS This is one of the documents that accountants and tax professionals are paying special attention to in 2026, especially as it directly relates to the conditions for deducting input VAT for goods purchased on deferred payment or installment plans. One of the most notable points of Circular 2398/CT-CS is the requirement that goods and services valued at 5 million VND or more must have non-cash payment documentation to be eligible for tax deduction.
So, is it mandatory for businesses to make a bank transfer right from the start? What happens if the payment deadline arrives and there is no bank transfer document? This article will provide a full analysis of Circular 2398/CT-CS, helping businesses understand correctly and avoid risks when settling taxes.
Context and necessity of Official Letter 2398/CT-CS
Official document 2398/CT-CS, issued by the Tax Department on April 15, 2026, provides guidance on VAT policy for goods and services purchased on deferred payment or installment plans with a value of 5 million VND or more.
The main focus of Official Letter 2398/CT-CS revolves around the application of:
- Clause 2, Article 14 of the Value Added Tax Law 2024
- Article 25 Decree 181/2025/ND-CP
- Article 26 of Decree 181/2025/ND-CP
Accordingly, businesses wishing to deduct input VAT must meet the requirements for valid invoices and non-cash payment documents for transactions that are subject to mandatory VAT deductions.
Is it mandatory to pay by bank transfer for installment payments of 5 million VND or more?
The answer is Yes, if the business wants to deduct input VAT.
According to Official Letter 2398/CT-CS, for goods and services purchased on deferred payment or installment plans with a value of 5 million VND or more (including VAT), businesses must have:
- Written sales contract
- Valid VAT invoice
- Non-cash payment vouchers
This means that if a business purchases goods on installment plans worth 5 million VND or more but only pays in cash, it will not be eligible to deduct input VAT.
Is it possible to claim a tax deduction if the payment is not yet due?
This is a very important point in Official Document 2398/CT-CS.
If a business purchases goods on installment but the payment due date according to the contract or contract addendum has not yet arrived, even without non-cash payment documentation, the business is still allowed to temporarily deduct input VAT.
For example:
- The company purchased equipment worth 50 million VND.
- The contract stipulates payment after 60 days.
- At the time of receiving the invoice and filing the tax return, the payment deadline had not yet arrived.
Result: Businesses are still allowed to claim input VAT deductions. This regulation helps businesses avoid interruption in their right to deduct VAT simply because the actual payment due date has not yet arrived.
What happens if the transfer isn't completed by the deadline?
This is the content that many accountants need to pay special attention to in Official Letter 2398/CT-CS.
If, at the time of payment as stipulated in the contract, the business does not have non-cash payment documentation, then the business must:
Declare a downward adjustment to the amount of input VAT already deducted.
This adjustment must be made in the tax period in which the payment obligation arises under the contract or contract addendum.
That is:
- Previously deducted.
- But when the payment deadline arrived, they failed to transfer the money as required.
The input VAT must be adjusted downwards accordingly. This is mandatory according to Circular 2398/CT-CS, not an option for businesses.
After the downward adjustment, is it still eligible for a deduction?
According to Official Letter 2398/CT-CS, if, after declaring a reduction in input VAT, the enterprise can provide valid non-cash payment documents, then the enterprise is allowed to declare and deduct that amount as prescribed.
This is important because it helps businesses avoid completely losing their right to deductions, instead allowing them to make adjustments as required by law.
However, to avoid complicated procedures, businesses should proactively control payment schedules and documentation from the outset.
What constitutes a valid non-cash payment document?
According to Article 26 of Decree 181/2025/ND-CP, as referenced in Official Letter 2398/CT-CS, non-cash payment documents are documents proving payment in accordance with the provisions of Decree 52/2024/ND-CP on non-cash payments.
Common forms include:
- Bank transfer
- Payment authorization
- Payment order
- Czech Republic
- Thanks to revenue
- Authorization for collection
Please pay special attention: A buyer depositing cash into the seller's account is not considered a non-cash payment. This is a very common mistake that causes many businesses to have expenses and input VAT disallowed during tax audits.
Important notes for business accountants.
To minimize the risk of errors when applying the guidelines in Official Letter 2398/CT-CS, businesses need to proactively review all large-value transactions, especially those with extended payment terms or those involving deferred or installment payments.
Tasks businesses should implement early.
Below are the key operational tasks that need to be prioritized to ensure compliance with regulations:
- Review the entire list of deferred payment and installment purchase contracts with a value of 5 million VND or more arising in the current accounting period to identify items that need to be tracked separately.
- Review and verify the legal validity of contract addendums in cases where the two parties adjust payment terms, extend payment deadlines, or change the content of the initial agreement.
- Organize and standardize relevant documents, including original contracts, electronic invoices, bank payment receipts, and debt reconciliation documents, to facilitate explanations when necessary.
- For complex business transactions such as debt clearing, payments through authorized parties, or transactions with multiple reciprocal elements, businesses should consult specialized solutions from... full accounting service of MAN – Master Accountant Network to ensure compliance and minimize tax risks.
Enhancing tax risk control for businesses.
Understanding and fully implementing the requirements of Official Letter 2398/CT-CS will not only help businesses avoid violations but also create a more sustainable financial management foundation. Specifically, businesses can:
- This helps to avoid being caught off guard during tax audits and prevents penalties from arising during the tax settlement period.
- Transparency in the declaration and deduction of input taxes protects actual cash flow and supports long-term financial planning.
- Building a well-structured and professional tax filing system creates an advantage in loan applications, audits, M&A activities, or other important financial transactions.
Conclude
Circular 2398/CT-CS is not only a guide on the conditions for deducting input VAT for goods purchased on deferred payment or installment plans, but also an important basis for businesses to effectively control tax risks during operation. Proactively reviewing contracts, standardizing payment documents, and ensuring compliance with legal requirements will help businesses avoid regrettable errors when settling taxes.
In the context of increasingly stringent tax regulations, early preparation is always the biggest advantage. If your business is facing difficulties in determining deduction eligibility, processing complex payment documents, or needs to review tax records according to the latest regulations, MAN – Master Accountant Network will be a reliable partner. With over 30 years of experience in accounting, tax, and corporate risk management consulting, MAN helps businesses optimize compliance, protect cash flow, and build a solid financial foundation for long-term growth.
Contact For free support and advice!
Contact information MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
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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.
Frequently Asked Questions about Official Document 2398/CT-CS
This ensures authenticity. If a transfer is made from an unfamiliar account not under the company's management, the transaction could be suspected of being fraudulent. Circular 2398/CT-CS requires consistency in the tax data system.
A tripartite contract and transparent financial transaction documents are required between the business, the finance company, and the seller. All cash flows must leave a digital trace on the banking system to ensure compliance.
This depends on the nature of the transaction and the accompanying supporting documents. If the offsetting of debts is accompanied by complete reconciliation statements, confirmation of debts between the parties, and complies with tax laws, the tax authorities may accept it. However, this is a high-risk transaction, so businesses need to carefully review it before applying it.
In many cases, businesses can still claim VAT deductions in advance if they have complete and legitimate invoices, sales contracts, and clear deferred or installment payment terms. However, after the payment deadline as stipulated in the contract, if the business cannot provide non-cash payment documentation, it must declare an adjustment to reduce the previously deducted VAT.
Yes. According to the guidelines in Official Letter 2398/CT-CS, for goods and services purchased on deferred payment or installment plans with a value of 5 million VND or more (including VAT), businesses must still meet the non-cash payment requirement to be eligible for input VAT deduction. Without valid bank payment documentation, this tax amount may be disallowed during tax settlement. Why does Official Letter 2398/CT-CS emphasize payment through an account registered with the tax authorities?
What should you keep in mind if you're paying in installments through intermediaries like finance companies?
Is debt offsetting considered a non-cash payment?
If a business has not paid its input VAT by the tax filing deadline, is it still eligible for deduction?
Is it mandatory for businesses purchasing goods on deferred payment or installment plans exceeding 5 million VND to make payments through a bank?
