Official document No. 6010/CT-CS The Tax Department's December 15, 2025, issued particularly important guidelines regarding the adjustment of input VAT for deferred payment and installment purchase transactions. According to the latest regulations, businesses need to pay special attention to the payment deadlines in contracts to avoid the risk of tax arrears or administrative penalties in the tax field. Understanding this document helps accountants proactively review accounts payable and make timely supplementary declarations in accordance with the regulations. Value Added Tax Law No. 48/2024/QH15.
In the context of Decree 181/2025/ND-CP, which has just come into effect, Circular No. 6010/CT-CS serves as a guiding principle to clarify the conditions for non-cash payment documents. For shipments valued at 5 million VND or more, delayed payment compared to the commitment in the contract appendix not only affects the business's reputation but also directly reduces the amount of deductible tax. This article will analyze in depth the legal and practical aspects of implementing this regulation to protect the maximum interests of businesses.
The key legal basis for regulation is Official Letter No. 6010/CT-CS.
To understand why Official Letter No. 6010/CT-CS requires tax reduction declarations, we need to examine the existing legal framework. Specifically, Clause 2, Article 14 of the Value Added Tax Law No. 48/2024/QH15 established a new threshold for cashless payments, creating a significant change in the accounting department's input invoice management process.
Furthermore, Articles 25 and 26 of Decree 181/2025/ND-CP provide detailed regulations on accepted non-cash payment methods. The issuance of Official Letter No. 6010/CT-CS aims to address the difficulties arising when businesses purchase goods on deferred payment terms but fail to fulfill their payment obligations as initially agreed with the supplier.
Regulations on the threshold value of goods according to Official Letter No. 6010/CT-CS
One of the key points of Circular No. 6010/CT-CS is the determination of the transaction value threshold for adjustment. Accordingly, the threshold of 5 million VND (including VAT) becomes the mandatory milestone requiring bank payment documentation to be eligible for input tax deduction.
Accountants should note that Circular No. 6010/CT-CS applies not only to individual invoices but also to the total value of transactions on the same day between the buyer and the seller. This requires close control over accounts payable to ensure compliance with current tax laws.
| Comparison content | Old regulations (Before 2025) | According to Official Letter No. 6010/CT-CS |
| Non-cash payment threshold | 20 million VND or more | From 5 million VND or more |
| Time of tax reduction adjustment | Usually when paying with cash. | As soon as the payment due date according to the contract arrives. |
| Basis for adjustment | Invoices and payment vouchers | Contract/Attachment to contract & Bank documents |
| Procedures when documents are available | Supplementary declaration | The deduction should be re-declared in the period in which the document was issued. |
Time of filing for adjustment to reduce input tax
According to the guidelines in Official Letter No. 6010/CT-CS, the obligation to adjust tax reduction arises in the tax period when the payment deadline stipulated in the contract has expired. For example, if the contract stipulates payment on November 30, 2025, but the enterprise has not yet transferred the funds by that date, then... VAT declaration In November 2025 (or Q4 2025), the accountant must make the deduction.
Accurately determining the deadline as stipulated in Official Letter No. 6010/CT-CS helps businesses avoid late payment penalties. If businesses ignore this regulation and are discovered by the tax authorities during an inspection, the penalty can amount to 20% of the underdeclared tax plus daily late payment interest as prescribed by the Tax Administration Law.
Instructions on how to handle situations when non-cash payment documents are unavailable.
Official document No. 6010/CT-CS clearly states that if, at the time of payment, there is no non-cash payment receipt, a reduction must be declared. This is a regulation that "enforces" transparency in commercial transactions. This applies to both the value of goods and services recorded on the invoice.
It should be understood that Official Letter No. 6010/CT-CS considers the lack of timely payment documents as a sign of not meeting the conditions for temporary deduction. Therefore, the accountant must record a reduction in item [37] on the 01/GTGT declaration form to accurately reflect the actual amount of eligible input tax at that time.
Procedure for deduction after payment as per Official Letter No. 6010/CT-CS
A positive sign from Circular No. 6010/CT-CS is the mechanism allowing for "re-deduction". If, after declaring a reduction, the enterprise ultimately makes payment to the supplier via bank transfer, they have the right to declare an additional deduction for this tax amount in the tax period in which the payment document is issued.
This procedure, as outlined in Official Letter No. 6010/CT-CS, helps ensure fairness for businesses facing temporary cash flow difficulties. However, these documents must be valid, legal, and correspond to the value of goods recorded in previous periods in order to be accepted for deduction.
Control contract addendums and related tax risks.
The management of contract addendums is a key focus of Circular No. 6010/CT-CS. If a business extends its debt through a contract addendum before the original payment due date, the tax adjustment period will be postponed to the new deadline. This opens up an optimal solution for accountants to maintain the deductible tax amount.
However, Circular No. 6010/CT-CS also warns against the abuse of contract addendums to delay tax obligations. Tax inspectors will compare the actual goods and the financial capacity of the enterprise to determine the authenticity of these debt extension agreements during inspections and audits.
The impact of Official Letter No. 6010/CT-CS on auditing work.
When reviewing the 2025 financial statements, auditors will use Circular No. 6010/CT-CS as a basis for assessing potential tax risks. Non-compliance with regulations on adjusting for tax reductions on deferred payment goods may result in a potential tax liability that needs to be disclosed in the report.
From a management perspective, Circular No. 6010/CT-CS encourages businesses to improve their ERP systems and accounts receivable management. Automating debt reminders and deadline warnings, in line with the spirit of this document, will minimize human errors and optimize tax costs for organizations.
FAQ – Frequently Asked Questions about Official Document No. 6010/CT-CS
What happens if I pay a 6 million VND bill in cash?
According to Official Letter No. 6010/CT-CS, in this case, you are absolutely not allowed to deduct input VAT. If you have already declared it, you must adjust it downwards immediately.
I bought something on a 12-month installment plan, paying a small amount each month. How should I declare this?
You must follow the payment schedule in the contract. For any installments that are not paid on time, declare a reduction in value as per Official Letter No. 6010/CT-CS.
Do the regulations in Official Letter No. 6010/CT-CS apply to individual business owners?
Yes, the regulation applies to all businesses paying VAT using the deduction method when transactions involving deferred payment for goods and services occur.
Conclude
Official document No. 6010/CT-CS represents a decisive step by the tax authorities in tightening the management of cash flow and ensuring the integrity of deferred payment transactions. Timely understanding of the guidelines in this document not only helps businesses comply with the law but also provides a basis for effective financial management, avoiding unnecessary legal risks in the future.
If your business is having difficulty implementing the regulations in Official Letter No. 6010/CT-CS or needs more in-depth advice on how to review tax liabilities, please contact MAN – Master Accountant Network immediately. We have a team of experienced professionals in the field. audit In the field of tax accounting, we are committed to providing optimal solutions that help protect businesses' interests to the fullest extent during complex tax audits.
Service contact information at MAN – Master Accountant Network
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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.
