VIETNAM LOGISTICS: A GUIDE TO INVOICING FREIGHT TRANSPORTATION SERVICES UNDER THE LATEST REGULATIONS

1. General Rules on Invoice Issuance Time

According to Article 1 of Decree No. 70/2025/ND-CP, which amends and supplements Decree No. 123/2020/ND-CP on invoices and documents, we have the following points:

• First, according to Decree No. 70/2025/ND-CP, the time of invoice issuance for services in general is when the service is completed, regardless of whether payment has been received. However, if the service provider receives money before or during the service, the invoice must be issued at the time of payment.
• Second, there is an exception: this rule does not apply to deposits or advance payments intended to secure the performance of contracts for specific services (e.g., accounting, auditing, financial and tax consulting, valuation, technical surveys and design, supervision consulting, and investment project preparation).
• Third, for services provided in large quantities, on a regular basis, that require time for data reconciliation (such as logistics services), the invoice issuance time is when the data reconciliation is completed. This must be done no later than the 7th day of the month following the month the service was provided, or no more than 7 days from the end of the agreed-upon reconciliation period.

2. Two Scenarios for Freight Transportation Services

So, how is invoicing handled specifically for freight transportation services? Based on the nature of the service and legal regulations, we can divide the process into two main scenarios, referencing Official Letter No. 4421/TCS3-QLDN2 on the timing of invoice issuance for freight transportation services:

Scenario 1: Frequent Freight Services Requiring Data Reconciliation

If your company’s freight transportation activities meet the conditions for logistics business as stipulated in Decree No. 163/2017/ND-CP, and your business provides services in large volumes, on a frequent basis, and requires time to reconcile data with customers, you are permitted to issue the invoice when the data reconciliation is completed. This must be done no later than the 7th day of the month following the service’s occurrence or no more than 7 days from the end of the agreed-upon reconciliation period.

Example: A transportation company signs a lump-sum freight contract with a factory for one quarter. The two parties agree to reconcile and make payments at the end of each month. In this case, the transportation company can issue the invoice upon completion of the reconciliation, but no later than the 7th day of the following month.

Scenario 2: Other Cases

If a business does not fall into the above category (e.g., providing a one-time service, irregularly, or without the need for reconciliation), the invoicing process is simpler. The time of invoice issuance will be when the freight transportation service is completed.

Example: An individual hires a truck for a single move. The invoice will be issued immediately after the transportation is completed, regardless of the payment time.

Understanding these regulations not only helps businesses comply with the law but also ensures transparent and efficient accounting and financial operations. If you require further consultation, please contact TPM for detailed support.