Issue an invoice for giving away mooncakes to customers. This is a business practice that needs attention when showing appreciation to customers, partners, and employees during the Mid-Autumn Festival 2026. Accountants need to correctly determine the timing of invoice issuance, the VAT taxable value, and the supporting documents to record reasonable expenses when calculating corporate income tax and personal income tax obligations for employees. Understanding the regulations at Decree 254/2026/ND-CP, Decree 253/2026/ND-CP And Decree 181/2025/ND-CP helps businesses comply with regulations and minimize legal risks.
During each Mid-Autumn Festival season, tax authorities thoroughly review input and output invoices related to corporate gift-giving activities. Failure to issue invoices or incorrect application of tax rates (8%) is a serious concern. Decree 174/2025/ND-CP This can lead to businesses being subject to tax arrears and administrative penalties for tax evasion or issuing invoices incorrectly. With 30 years of experience in comprehensively analyzing current regulations, MAN's team of experts provides optimal tax risk management solutions for the business community.
A summary of key points regarding how to issue invoices for mooncake gifts to customers in 2026.
- Define: Issuing invoices for gifting mooncakes to customers means that businesses create electronic invoices to record transactions involving the sale of goods for gifting to partners, customers, or employees without collecting payment.
- Purpose: Record the output VAT obligation in accordance with the law and use it as a legal basis to include the cost of purchasing gifts as a deductible expense when settling corporate income tax.
- Applicable objects: All businesses and economic organizations that purchase mooncakes or produce their own mooncakes for gifting purposes are included.
- Time of execution: Issue an invoice immediately upon transferring ownership or the right to use the mooncakes to the recipient.
- VAT and Personal Income Tax Rates: The VAT rate of 8% will be applied according to the tax reduction policy extended throughout 2026. Giving mooncakes as gifts in kind is not subject to personal income tax on gifts (unless it is included in income in the nature of salary or wages).
Legal regulations regarding issuing invoices for gifting mooncakes to customers.
The giving and gifting of goods in general, and mooncakes in particular, is governed by the legal regulations on electronic invoices and VAT. Businesses need to understand the legal basis to comply correctly from the outset.
Issuing invoices is mandatory when giving mooncakes as gifts, according to Decree 254/2026/ND-CP.
Clause 1, Article 4 Decree 254/2026/ND-CP Regarding the principles of creating, managing, and using electronic invoices and documents, it is clearly stipulated that: When selling goods or providing services, the seller must create an electronic invoice to give to the buyer. This regulation applies even to cases where goods are used for promotions, advertising, samples, or goods used for giving away, gifting, exchanging, paying as compensation to employees, and internal consumption.
Therefore, even if a business gives mooncakes to customers or employees free of charge, issuing an electronic invoice is still a mandatory obligation (except for cases where electronic invoices are not required under Article 7 of Decree 254/2026/ND-CP). The act of giving gifts without issuing an invoice is considered a violation of invoice regulations by the tax authorities and carries the risk of having its taxable revenue assessed. VAT.
Issue a single consolidated invoice along with a detailed list of recipients.
In practice, management in medium and large-sized businesses shows that issuing individual invoices to hundreds of customers or employees receiving mooncakes puts significant pressure on the accounting department. To reduce administrative procedures, the law has allowed for a mechanism of consolidated invoicing.
Point a.3, Clause 5 of the Appendix issued with Decree 254/2026/ND-CP allows businesses to issue a single electronic invoice for giving away or gifting mooncakes in large quantities. On this invoice, the buyer's name field should clearly state "Customer not requesting an invoice" or "List of customers and employees receiving gifts attached". The business must prepare a detailed list showing the full names of recipients, quantities, and types of mooncakes, with confirmation from the relevant department.
The timing of invoicing for gifts is governed by Article 9 of Decree 254/2026/ND-CP.
The time of invoice issuance for goods given as gifts is stipulated in Clause 1, Article 9 of Decree 254/2026/ND-CP. Accordingly, the time of issuing an invoice for the sale or gift of goods is the time of transferring ownership or the right to use the goods to the recipient, regardless of whether payment has been received or not.
Accountants are not allowed to hoard gift vouchers from the beginning of the season and only issue invoices at the end of the quarter or year. Delaying invoice issuance compared to the actual delivery time will result in administrative penalties from the tax authorities for invoice timing violations.
Determining the taxable value and tax rate when issuing invoices for mooncakes given as gifts to customers.
The basis for calculating VAT on gifted goods depends on whether the gift is a simple token of appreciation or a legally registered promotional program.
The VAT taxable value for ordinary gifts.
Clause 1, Article 6 of Decree 181/2025/ND-CP stipulates: For goods used for exchange, internal consumption, gifts, or donations, the VAT taxable price is the VAT taxable price of similar or equivalent goods and services at the time these activities occur.
If a business purchases mooncakes from a supplier to give to customers, the VAT taxable price on the output invoice is usually the purchase price excluding VAT or the listed retail price of that type of mooncake on the market. Accountants use this price to calculate the output VAT payable.
The VAT taxable price for legitimate promotional activities.
Clause 2, Article 6 of Decree 181/2025/ND-CP applies specific regulations for promotional goods. If a business implements a mooncake giveaway program in accordance with the law on commerce (having completed the registration or notification procedures with the Department of Industry and Trade), the VAT taxable value of the promotional mooncakes is determined to be 0.
For example, if a business implements a promotion "Buy 20 cartons of goods and receive 1 box of mooncakes free" and has notified the Department of Industry and Trade, the VAT taxable price on the invoice for the free box of mooncakes will be recorded as 0 VND. Without registering the promotion according to the Commercial Law, the business is required to declare the taxable price based on the market price.
Apply VAT rate 8% according to Decree 174/2025/ND-CP
Mooncakes, classified as processed foods, are not included in the list of goods subject to VAT under Article 10% and are not subject to tax reduction as stipulated in the legal appendices accompanying Decree 174/2025/ND-CP.
The policy of reducing the VAT rate by 2% will continue until December 31, 2026. Therefore, when issuing invoices for mooncakes given as gifts in 2026, businesses should apply the VAT rate of 8%. Accountants need to ensure that the tax rate line correctly reflects 8%, and not leave it blank or indicate that it is not tax-exempt.
Conditions for deducting corporate income tax expenses and personal income tax obligations when giving mooncakes as gifts.
In addition to fulfilling output VAT obligations, managers need to understand the conditions for including mooncake purchase costs as deductible business expenses and the personal income tax obligations for employees.
Three conditions for deductible expenses according to the Corporate Income Tax Law 2025 and Decree 320/2025/ND-CP.
According to Clause 1, Article 9 of the Corporate Income Tax Law 2025 and Article 9 of Decree 320/2025/ND-CP, expenses for purchasing mooncakes as gifts for customers and employees are deductible if they meet all three conditions:
- Actual expenses incurred in connection with production and business activities: Customer appreciation gifts help maintain cooperative relationships and boost sales; employee gifts aim for welfare and improve productivity.
- Complete and legally valid invoices and documents: The business has input VAT invoices for purchased cakes, output VAT invoices for gifts, a decision approving the gift-giving budget, a sales contract, and a list of signed receipts.
- Non-cash payment documents: This applies to purchase invoices with a total payment value of 5 million VND or more (including VAT).
Stricter regulations on cashless payments starting from 5 million VND.
The Corporate Income Tax Law of 2025 introduces new regulations regarding the threshold for non-cash payments. The mandatory threshold for bank payment documentation has been lowered from VND 20 million to VND 5 million.
Experts at MAN, with 30 years of experience, note that if a mooncake purchase invoice is worth 5 million VND or more but the business pays with cash, the entire cost will be excluded from deductible expenses during tax settlement. corporate income tax. At the same time, the corresponding input VAT amount is also not deductible.
Control employee welfare expenses.
In the case of purchasing mooncakes as gifts for company employees, this expense is classified as a direct employee welfare expenditure.
The Corporate Income Tax Law stipulates that the total amount of welfare-related expenses must not exceed one month's average actual salary paid during the tax year. Accountants need to consolidate the cost of mooncakes along with other welfare expenses (weddings, funerals, sightseeing trips, vacations, medical support) to ensure they do not exceed the prescribed limit.
Analysis of personal income tax obligations according to Decree 253/2026/ND-CP
One common question among businesses is whether giving mooncakes to employees is subject to personal income tax. According to Decree 253/2026/ND-CP, the tax liability is determined as follows:
Case 1: Giving a gift in kind (mooncakes) as a regular gift.
- Based on Article 15 Decree 253/2026/ND-CP Regulations regarding income from inheritance and gifts subject to personal income tax include: capital contributions in economic organizations; securities; real estate; assets requiring registration of ownership or use rights (cars, motorcycles, boats, airplanes, etc.).
- Since mooncakes are considered ordinary assets and are not included in the list of assets requiring registration of ownership or usage rights under Article 15 of Decree 253/2026/ND-CP, employees receiving mooncakes as gifts are not subject to personal income tax on gifts. Therefore, businesses giving mooncakes as gifts to employees will not be liable for tax. personal income tax Regarding this gift.
Case 2: Gifts in the form of salary or wages.
- In cases where a business converts gifts into cash or pays gift expenses in the nature of salary or wages to employees (who have signed labor contracts), the value of the gift will be included in taxable income from salary and wages as stipulated in Clause 2, Article 8 of Decree 253/2026/ND-CP.
- For resident individuals who do not have a labor contract or have a labor contract of less than 3 months and receive this salary or wage payment, the enterprise shall deduct personal income tax in accordance with the provisions of Article 50 of Decree 253/2026/ND-CP.
Compilation of the latest legal documents and guidance letters in 2026
The legal framework governing the invoicing and taxation of mooncake gifts in 2026 includes the following documents:
| Document Name / Document Number | Issuing authority | Summary of revised content |
| Decree 254/2026/ND-CP | Government | Regulations stipulate the mandatory issuance of electronic invoices when giving gifts or presents to customers and employees (Clause 1, Article 4); allow the issuance of a summary invoice accompanied by a list of items (Appendix); and specify the time of invoice issuance (Article 9). |
| Decree 253/2026/ND-CP | Government | Regulations on taxable gifts subject to personal income tax (Article 15); taxable income from salaries and wages (Article 8); regulations on personal income tax deduction (Article 50). |
| Decree 181/2025/ND-CP | Government | The regulations stipulate that the VAT taxable value for gifts is equal to the price of similar or equivalent goods; legally compliant promotional goods have a taxable value of 0 (Article 6). |
| Decree 174/2025/ND-CP | Government | The policy of reducing the VAT rate by 2% (from 10% to 8%) for mooncakes will be extended until December 31, 2026. |
| Corporate Income Tax Law 2025 | National Assembly | Regulations stipulate the conditions for deductible expenses and lower the threshold for non-cash payment documents to 5 million VND (Clause 1, Article 9). |
| Decree 320/2025/ND-CP | Government | Guidelines for implementing the Corporate Income Tax Law 2025 regarding invoices, bank payment documents, and welfare expenditure limits. |
| Official Document 6154/CTH-QLDN1 | Tax Department | Detailed instructions on creating electronic invoices for gifts and presents to customers, and guidance on declaring output and input VAT. |
Analyzing a Real-World Case Study in a Vietnamese Business
To clearly understand the implementation process and accounting methods, let's analyze a real-world case study that was advised by experts at MAN.
A real-life situation at Minh Phong Trading Joint Stock Company
In August 2026, Minh Phong Trading Joint Stock Company (Minh Phong Company) purchased 200 boxes of mooncakes from a supplier to give as gifts to partners and customers on the occasion of the Mid-Autumn Festival.
- Quantity purchased: 200 boxes of cookies.
- Purchase price: 500,000 VND/box (excluding VAT).
- Total price of goods before tax: 100,000,000 VND.
- Input VAT (8%): 8,000,000 VND.
- Total payment amount: 108,000,000 VND (transferred from the company account).
- Purpose: To show appreciation to loyal customers; not registered as a promotional program with the Department of Industry and Trade.
Steps for processing documents and accounting entries.
The company follows the steps for processing according to tax accounting standards:
Step 1: Record the incoming purchase invoices.
Upon receiving the VAT invoice from the cake supplier, the accountant made a bank transfer payment of VND 108,000,000.
Accounting for the cost of purchasing gifts:
- Debit Account 641 (Selling Expenses): 100,000,000 VND
- Debit Account 1331 (Deductible VAT): 8,000,000 VND
- Account 1121 (Bank Deposits): 108,000,000 VND
Step 2: Generate an electronic invoice when giving out gifts.
At the time of handing over the cakes to customers, the accountant prepares an electronic invoice for the gift, along with a list of 200 customers who received the gifts.
Items to be included on the issued invoice:
- Product Name: Mooncakes for Customer Appreciation (Attached is the list of customers No. 01/TT)
- VAT taxable price: 500,000 VND/box
- Total amount: 100,000,000 VND
- VAT rate: 8%
- VAT amount: 8,000,000 VND
- Total payment amount: 108,000,000 VND
Accounting for output VAT obligations:
- Debit Account 641 (Selling Expenses): 8,000,000 VND
- Account 33311 (VAT payable): 8,000,000 VND
Results of tax risk management at Minh Phong Company
After completing the process:
- Impact of VAT: Input VAT is deductible at VND 8,000,000, and output VAT payable is VND 8,000,000. The VAT obligations balance, and the tax cash flows cancel each other out.
- Impact of corporate income tax: The total cost of purchasing cakes (VND 100,000,000) plus the output VAT paid on behalf of the customer (VND 8,000,000) is VND 108,000,000, which is fully included in the deductible selling expenses. The corporate income tax saved by the business is VND 108,000,000 x 20% = VND 21,600,000.
- Impact of personal income tax: Since the customer is an external partner and mooncakes are not classified as assets requiring registration, the transaction does not generate any personal income tax liability.
- Document security: A complete set of documents makes it easier for businesses to explain their financial statements when the tax authorities conduct an audit.
Comparing the options for invoicing regular gifts and promotional gifts.
The differences between the two forms of gift-giving are shown in the comparison table below:
| Classification criteria | Typical thank-you gifts | Gifts as Promotional Items |
| Legal basis | Clause 1, Article 6 of Decree 181/2025/ND-CP | Clause 2, Article 6 of Decree 181/2025/ND-CP |
| Administrative procedures | No notification to the trade regulatory authority is required. | Registration or notification to the Department of Industry and Trade is required. |
| VAT unit price | Listed selling price/buying price at the same time. | Recorded as 0 VND. |
| Output VAT number | Pay 8% based on the taxable value. | Equal to 0 VND. |
| Input VAT deduction | Deductible if supported by invoices and bank documents. | Deductible if supported by invoices and bank documents. |
| Calculating reasonable costs for corporate income tax. | Included in the cost of goods sold/benefits. | Included in sales/promotional expenses. |
MAN Expert Opinion: 5 Common Tax Risks and Optimal Solutions
Through practical experience advising and working with tax authorities nationwide, experts at MAN have identified the 5 most common mistakes that Vietnamese businesses often make during the Mid-Autumn Festival season.
Risk 1: Failure to issue electronic invoices for outgoing transactions.
Many accountants believe that gifts and presents do not generate cash revenue and therefore do not require invoices. However, during tax audits, tax officials will compare the quantity of cakes purchased on input invoices with the inventory quantity. If cakes are found to have been shipped without output invoices, the tax authorities will determine the revenue, collect back VAT, and impose a fine of 1 to 3 times the amount of tax evaded.
The solution from MAN: Establish internal control regulations. The warehouse and accounting departments must finalize the quantity of cakes distributed as gifts weekly. The accounting department must immediately create electronic invoices for the gifts after the cakes are delivered.
Risk 2: Arbitrarily recording a price of 0 VND without registering a promotion.
Some businesses record a unit price of 0 VND on gift invoices, claiming it's a "free gift." If they cannot provide documentation confirming notification of the promotion to the Department of Industry and Trade, the tax authorities will reject this 0 VND unit price, adjust the taxable price according to market price, and penalize the business for issuing invoices incorrectly.
The solution from MAN: Clearly define the nature of the program. For typical customer appreciation events, the correct purchase price/listed price must be recorded, along with the applicable tax (8%). If a price of 0 VND is desired, the sales department must complete the promotional notification as required by the Commercial Law before the gift is given.
Risk 3: Paying cash for cake orders exceeding 5 million VND.
According to the 2025 Corporate Income Tax Law, the mandatory bank payment threshold has been reduced to 5 million VND. However, some companies are still using their existing cash reserves to pay for mooncakes worth 6 or 7 million VND.
The solution from MAN: Transfer all gift purchase transactions of 5 million VND or more to a bank account under the company's name. Absolutely do not use cash or transfer funds from employees' personal accounts to pay suppliers directly.
Risk 4: Documentation lacking a list of gift recipients.
Even with sufficient purchase and sales invoices, if the business cannot prove the list of actual customers or employees who received the cakes, tax inspectors have the right to disallow this expense as a deductible business expense due to suspected fictitious spending.
The solution from MAN: Prepare a complete set of gift documents including: Proposal for Mid-Autumn Festival budget approval -> Sales contract and purchase invoices -> Board of Directors' decision to give gifts -> List of customers signing for mooncakes or handover record -> Electronic sales invoice with accompanying summary.
Risk 5: Confusion between gifts in kind and income from salary when calculating personal income tax.
Some accounting departments inadvertently add the value of mooncakes to employees' taxable income for personal income tax purposes, or conversely, convert them into cash but omit calculating personal income tax.
The solution from MAN: Clearly distinguish between the forms of gifting. Gifting physical cakes is not subject to personal income tax on received gifts according to Article 15 of Decree 253/2026/ND-CP. However, if converted into cash and included in salary income, it must be added to taxable personal income according to Article 8 of Decree 253/2026/ND-CP.
Conclude
Issuing invoices for mooncake gifts to customers and employees in accordance with legal standards is a crucial requirement for businesses to demonstrate professionalism in their appreciation activities while thoroughly controlling tax risks. Full compliance with the regulations in Decree 254/2026/ND-CP, Decree 253/2026/ND-CP, Decree 181/2025/ND-CP, and the Corporate Income Tax Law 2025 will help businesses protect their right to deduct input VAT and optimize reasonable expenses when settling corporate income tax.
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Responsible for production and professional content review by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant Network, CPA Vietnam with over 30 years of experience in accounting, auditing, taxation, and corporate financial consulting.
Frequently Asked Questions (FAQ) about invoicing customers for mooncakes as gifts.
Can businesses that purchase mooncakes to give as gifts to customers deduct input VAT?
Yes. Businesses are entitled to deduct the full input VAT on mooncakes purchased for gifting purposes if they have a valid VAT invoice, non-cash payment documentation (for invoices of 5 million VND or more), and issue an output VAT invoice when giving them as gifts.
Do we need to issue invoices when giving mooncakes as gifts to company employees?
Yes. According to Clause 1, Article 4 of Decree 254/2026/ND-CP, giving mooncakes to employees falls under the category of gifts, donations, or internal consumption. Businesses are required to issue electronic VAT invoices with a tax rate of 8%, similar to giving them to customers.
Is giving mooncakes as gifts to employees subject to personal income tax?
No, if the gift is in kind. According to Article 15 of Decree 253/2026/ND-CP, mooncakes are not included in the list of gifts subject to personal income tax. However, if the gift is in cash and is considered as salary or wages, it must be included in taxable income according to Clause 2, Article 8 of Decree 253/2026/ND-CP.
Is there a limit on the cost of purchasing mooncakes as gifts for employees?
Yes. The expense of purchasing mooncakes for employees falls under the welfare expense category. The total welfare expense for the year must not exceed one month's average actual salary paid during the tax year of the enterprise.
On an invoice for mooncakes given to customers, how should the "Buyer's Name" field be filled in?
In cases where a single invoice is issued for multiple customers receiving gifts, under the "Buyer's Name" field, the accountant should record: "Customer did not request an invoice" or "List of customers receiving gifts attached".
