Decree 144/2026/ND-CP Amends VAT Law Implementing Regulations - New VAT Exemptions, Revised Input Credit Rules, Updated List of Exported Minerals

Document Information

• Reference number: 144/2026/ND-CP
• Issue date: May 5, 2026
• Effective date: June 20, 2026
• Issuing authority: Government of Vietnam
• Amends: Decree 181/2025/ND-CP dated July 1, 2025 (as amended by Decree 359/2025/ND-CP), which details implementation of VAT Law No. 48/2024/QH15 (as amended by Law No. 90/2025/QH15 and Law No. 149/2025/QH15)

Expanded list of VAT-exempt items (Article 1)

The decree adds clause 3a to Article 4 of Decree 181/2025/ND-CP, expanding the group of VAT-exempt insurance products to include:

• Life insurance, health insurance, student insurance, and other insurance services related to individuals
• Livestock insurance, crop insurance, and other agricultural insurance services
• Insurance for boats, ships, equipment, and tools used directly for fishing
• Reinsurance under insurance business law
• Insurance for oil and gas facilities, equipment, and foreign-flagged oil tankers leased by foreign petroleum contractors or subcontractors to operate in Vietnamese waters or overlapping waters under joint exploitation arrangements

The decree also amends point dd, clause 4, Article 4: the VAT-exempt activity of 'debt sale' now explicitly includes the sale of payables, the sale of receivables, and the sale of deposit certificates.

Clause 14, Article 4, on exported natural resource/mineral products (see Appendix section below) is also amended - this is the basis for applying the state's policy of discouraging and restricting raw mineral exports. When the list needs adjustment to fit socio-economic conditions, the Ministry of Industry and Trade proposes changes, and the Ministry of Finance leads coordination with relevant ministries to report to the Government for a decision.

Revised revenue calculation under the direct method (Articles 2 and 3)

• Article 9: Agency commission revenue from selling VAT-exempt goods/services, and insurance brokerage commission revenue, are both confirmed as VAT-exempt for direct-method revenue calculation purposes.
• Article 23: A new point c is added to clause 2 - total revenue of VAT-taxable goods/services used for tax calculation now also includes revenue from goods that are not required to be declared or have VAT paid on them under clause 1, Article 5 of the VAT Law (as amended by Law No. 149/2025/QH15).

Revised input VAT credit rules for deferred-payment/installment purchases (Article 4)

For goods or services purchased on deferred payment or installment terms valued at VND 5 million or more, businesses use a written purchase contract, a VAT invoice, and non-cash payment documents to credit input VAT. Key changes:

1. If the contractual payment deadline has not yet arrived and non-cash payment documents are therefore not yet available, the business may still credit input VAT.
2. Once the contractual payment deadline arrives without non-cash payment documents, the business must declare a downward adjustment to the credited input VAT for the portion lacking valid documents, in the tax period when the payment obligation arises.
3. If, after the adjustment, the business subsequently obtains valid non-cash payment documents, it may re-declare and re-credit the corresponding VAT amount in the tax period the documents are obtained.

This change avoids forcing businesses to withhold input credit while waiting for a payment deadline, while still requiring timely correction if non-cash payment is not completed on time.

Replacement of the list of exported natural resource/mineral products (Article 5, Appendices I and II)

The decree replaces the entire list (Appendix I and Appendix II) issued with Decree 181/2025/ND-CP, used to identify exported products classified as natural resources/minerals subject to the state's restricted-export tax policy.

• Appendix I - Exported unprocessed natural resource/mineral products: covers HS categories under Chapter 25 (salt, sulfur, earth and stone, sand, gypsum, lime, asbestos, mica, etc.), Chapter 26 (ores and concentrates of iron, manganese, copper, nickel, cobalt, aluminum, lead, zinc, tin, chromium, tungsten, uranium, thorium, molybdenum, titanium, zircon, precious metals, slag and ash, etc.), and Chapter 27 (coal, lignite, peat, coke, crude petroleum, condensate, petroleum gases, mineral waxes, etc.).
• Appendix II - Exported processed natural resource/mineral products: covers HS categories under Chapter 28 (inorganic chemicals such as phosphorus, silicon dioxide, zinc oxide, titanium oxide, etc.), Chapter 71 (diamonds, precious and semi-precious stones, silver, gold, jewelry of precious metal), Chapter 72 (ferro-alloys, iron and steel scrap), Chapters 74-76 (copper, nickel, aluminum and their products), and Chapters 78-81 (lead, zinc, tin, and other base metals such as tungsten, molybdenum, tantalum, magnesium, cobalt, bismuth, titanium, zircon, antimony, manganese, chromium, etc.).

The lists are built on HS codes and product descriptions from Vietnam's current export/import tariff nomenclature. Businesses exporting minerals and metals should verify the specific HS codes against the tariff schedule in effect at the time of customs declaration to apply the correct treatment.

Effective date

The decree takes effect from June 20, 2026. Ministers, heads of ministerial-level agencies, chairpersons of provincial and municipal People's Committees, and related organizations and individuals are responsible for implementation.