Official document No. 6068/CT-CS The tax authority's regulations issued on December 17, 2025, have clarified one of the issues of greatest concern to businesses, accountants, and auditors today: whether VAT incurred before July 1, 2025, is eligible for the new refund policy. Decree 181/2025/ND-CP Whether or not. The content of this document directly impacts the preparation of tax refund applications, tax risk assessment, and legal compliance during the policy transition period.
In the context of stricter regulations on VAT refunds effective July 1, 2025, Circular No. 6068/CT-CS serves as a guiding principle, helping businesses determine the correct timing for policy application and avoid errors that could lead to refund rejections or tax audits. This article will provide a comprehensive analysis of the legal regulations, practical application, and important notes for accountants, auditors, and tax authorities.
Overview of Official Letter No. 6068/CT-CS and the context of its issuance.
Official document No. 6068/CT-CS was issued in the context of the legal system. VAT There will be significant changes from July 1st, 2025, when Decree No. 181/2025/ND-CP officially comes into effect. This decree specifies the subjects, conditions, and procedures. VAT refund, replacing and modifying much of the previous content.
According to the Tax Department, the time when the tax liability arises and the time when the tax refund is requested are two key factors in determining the applicable policy. Circular No. 6068/CT-CS not only explains the legal principles but also provides guidance on consistent application across the entire tax system, limiting differing interpretations between localities.
The legal basis cited is in Official Letter No. 6068/CT-CS
To clarify the application of the VAT refund policy for taxes incurred before July 1, 2025, Official Letter No. 6068/CT-CS cited all relevant legal grounds. The focus was on the effective date of Decree No. 181/2025/ND-CP and the principles of applying the law according to the Law on the Promulgation of Legal Documents. Correctly determining the effective date of the document and the policy application date is a crucial legal basis to help businesses, accountants, and auditors avoid misapplying VAT refund regulations during the policy transition period.
Decree No. 181/2025/ND-CP and its effective date.
According to Official Letter No. 6068/CT-CS, Decree No. 181/2025/ND-CP takes effect from July 1, 2025. This Decree stipulates the following:
- Subjects eligible for VAT refund
- Conditions for VAT refund
- Documents, procedures, and steps for tax refund
Determining the validity of Decree 181/2025/ND-CP is fundamental to analyzing the question of whether VAT incurred before July 1, 2025, will be subject to the new policy.
Principles for applying the law according to the Law on Promulgation of Legal Normative Documents
Official document No. 6068/CT-CS cites Article 58 of the Law on Promulgation of Legal Normative Documents, according to which:
“"Legal regulations are applied from the time they come into effect to acts and events occurring at the time the regulation is in effect."”
This principle clearly states that tax policies cannot be applied retroactively, except in cases that benefit the taxpayer and are explicitly stipulated in legal documents.
Will the new VAT refund policy apply to VAT incurred before July 1, 2025?
According to the conclusion in Official Letter No. 6068/CT-CS, VAT incurred before July 1, 2025 Not automatically applied The new tax refund policy under Decree 181/2025/ND-CP. The application of the tax refund policy depends on... tax refund application period, not just the time the tax is incurred.
Specifically, if a business requests a VAT refund on a monthly or quarterly basis, the VAT refund policy in effect at that time will apply. This is a crucial point that accountants and businesses need to pay special attention to.
Official document No. 6068/CT-CS has clarified the relationship between the time of tax liability, the time of eligibility for tax refund, and the time of submitting the tax refund application according to tax management law.
This applies to goods and services exported under Official Letter No. 6068/CT-CS.
Regarding export activities, Circular No. 6068/CT-CS clarifies how to determine the eligibility and conditions for VAT refund in the context of policy changes from July 1, 2025. The circular focuses on the relationship between the amount of uncredited input VAT, the timing of refund requests (monthly or quarterly), and the effectiveness of current legal regulations. This is an important basis for export businesses to correctly apply the VAT refund policy, minimizing risks when tax authorities inspect and audit refund applications.
Conditions for VAT refund on exported goods and services.
According to Official Letter No. 6068/CT-CS, if a business entity exports goods or services during the month or quarter and meets the following conditions, it is eligible for VAT refund:
- There is an amount of input VAT that has not been fully deducted from 300 million VND or more
- Meeting the conditions for VAT refund as stipulated by VAT law.
- There is a valid tax refund application in accordance with tax administration laws.
This applies to both the period before and after July 1, 2025, but the specific policy will depend on when the tax refund request is made.
Applying a monthly or quarterly tax refund policy.
Official document No. 6068/CT-CS emphasizes that businesses requesting VAT refunds on a monthly or quarterly basis will be subject to the VAT refund policy in effect for that month or quarter. This is a crucial principle during the policy transition period.
Comparison of VAT refund policies before and after July 1, 2025
To clarify the differences in VAT refund policies before and after July 1, 2025, Circular No. 6068/CT-CS needs to be considered in relation to the relevant legal regulations for each period. Comparing key criteria such as applicable documents, refund conditions, legal principles, and the level of audit risk helps accountants, auditors, and businesses clearly identify the practical impact of Decree 181/2025/ND-CP when preparing and reviewing VAT refund applications.
| Criteria | Before July 1, 2025 | Effective from July 1, 2025, according to Decree 181/2025/ND-CP |
| Applicable document | Value Added Tax Law, Old Decree | Decree 181/2025/ND-CP |
| Conditions for tax refund | More flexible | Tighten the conditions |
| Time of application | According to the tax refund request period | According to the tax refund request period |
| Legal principles | No retroactive effect | No retroactive effect |
| Risk of being inspected | Medium | Higher |
The table above helps accountants and auditors easily visualize the differences when applying Circular No. 6068/CT-CS in practice.
Practical impact of Official Letter No. 6068/CT-CS on businesses
Official document No. 6068/CT-CS directly impacts the VAT management strategy of businesses. Determining the correct refund period not only affects cash flow but also determines the level of risk when subject to tax audits and inspections.
Exporting businesses and businesses investing in large projects need to review all input VAT records, clearly classifying transactions by month and quarter to create a suitable tax refund plan. In reality, many businesses are denied tax refunds due to incorrect application of policies during the transition period.
Accounting, auditing, and tax perspectives on Official Letter No. 6068/CT-CS
From a professional perspective, Circular No. 6068/CT-CS helps standardize the understanding and application of VAT law throughout the entire system. This is an important basis for auditors to assess compliance when reviewing tax reports and financial statements.
For accountants, this document is mandatory to understand when preparing VAT refund applications for 2025-2026. Misunderstanding or incorrect application can lead to risks of tax arrears, late payment penalties, and damage to the company's reputation.
Conclude
Official document No. 6068/CT-CS is a highly practical guidance document that helps businesses, accountants, and auditors correctly determine VAT refund policies during the transitional period before and after July 1, 2025. Understanding and correctly applying this document will not only help businesses protect their VAT refund rights but also limit legal risks related to taxation.
In the context of increasingly stringent tax policies, MAN – Master Accountant Network is ready to partner with businesses with the following: auditing services, tax accounting, Reviewing VAT refund applications helps ensure legal compliance and optimize financial efficiency. Contact MAN today for expert advice and up-to-date information on the latest tax policies.
Service contact information at MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
- Mobile/Zalo: 0903 963 163 – 0903 428 622
- 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.
Frequently Asked Questions related to Official Letter No. 6068/CT-CS
According to Official Letter No. 6068/CT-CS, the applicable policy is determined not based on the time the tax is incurred, but on the time the tax refund is requested (monthly or quarterly).
The application process should be carefully considered based on the tax refund conditions and policies in effect at the time of the application, in accordance with the guidelines in Official Letter No. 6068/CT-CS.
The VAT refund procedure is carried out in accordance with the provisions of the current tax management law at the time of application submission, as stated in Official Letter No. 6068/CT-CS. Will VAT incurred before July 1, 2025, be refunded under the new policy?
Should businesses file for tax refunds before or after July 1, 2025?
Which document should be used for processing tax refund applications?
