🚨 OFFICIAL LETTER 5487/CT-CS (25/11/2025): LATE PAYMENT STILL ELIGIBLE FOR VAT CREDIT – IF PAID BY NON-CASH METHOD!
💥 Good news for businesses with deferred payments, installment payments, or overdue payments of VND 5 million or more.
Official Letter 5487/CT-CS clarifies one of the most confusing VAT issues in recent years.
🔍 Key Points of Official Letter 5487/CT-CS
✅ 1. If the payment deadline arrives but no non-cash payment evidence is available → the business MUST reverse the VAT input credit
Applicable when:
- Goods/services value is ≥ VND 5,000,000
- Payment is due under the contract but there is no bank transfer or no valid non-cash payment evidence
👉 The business is required to adjust and decrease previously credited VAT input.
🔥 2. After reversal, if the business later makes a valid non-cash payment → VAT input can be CREDITED AGAIN
Eligible when:
- The business completes the bank transfer, or
- Provides valid non-cash payment evidence as defined in Article 26 of Decree 181/2025
👉 The business may re-claim the input VAT amount previously reversed.
📌 This “re-credit mechanism” is NEW – and highly beneficial for businesses.
📘 Legal Basis
- 📄 Clause 2 Article 14 – VAT Law 2024 (Law 48/2024/QH15)
- 📄 Article 25 – Decree 181/2025 (invoice & tax documentation requirements)
- 📄 Article 26 – Decree 181/2025 (non-cash payment evidence)
💳 11 Accepted Non-Cash Payment Methods (Valid for VAT Input Credit)
These payment methods are recognized as compliant when supported by proper evidence:
- Bank transfer (❗cash deposits into seller’s account are NOT accepted)
- Offsetting between goods/services
- Offsetting loan/borrowing obligations
- Authorized payment via a legally recognized third party
- Payment by shares or bonds
- Remaining amount ≥ VND 5 million paid by bank transfer
- Payment to the State Treasury in compulsory enforcement cases
- Installment/deferred payment made by bank transfer on schedule
- Purchases < VND 5 million per transaction (non-cash payment not required)
- Employee pays first – company reimburses via bank transfer
- Multiple purchases in a day totaling ≥ VND 5 million → MUST use non-cash payment
🎯 Practical Meaning for Businesses
- 👍 No loss of VAT credit just because payment was late
- 👍 As long as non-cash payment is made afterwards → VAT can be credited again
- 👍 Businesses must track payment deadlines to avoid forced VAT reversal
📩 Need MBA Audit to review your payment documentation, VAT credit compliance, or non-cash payment evidence?
MBA Audit is always ready to support your business. 💚
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