Ministry of Finance: Clarification on Deductible Expenses for Purchases Above VND 5 Million Pending Payment - Non-Cash Payment Voucher Requirement (CIT)
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Based on:Nghị định số 320/2025/NĐ-CP; Thông tư số 20/2026/TT-BTC - Ministry of Finance
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The Ministry of Finance clarified the rules on deductible expenses for single purchases of goods or services worth VND 5 million or more that have not been paid at the time the expense is recognized, under Decree 320/2025/ND-CP and Circular 20/2026/TT-BTC. Under the regulations, when a company has not yet paid at the time of expense recognition, the cost may still be deducted if a contract and a goods/service handover record exist. However, when actual payment is eventually made without a non-cash payment voucher, the company must file a downward adjustment of the expense in the tax period in which the cash payment occurs - even if the tax authority has already issued an audit or inspection decision for that period. The Ministry of Finance noted that 'not yet paid' means payment has not actually been made at the time the expense is recognized, not merely that the contractual payment deadline has not yet arrived. Companies must monitor and adjust their declarations in the correct tax period.
Ministry of Finance Response: Deductible Expenses for Unpaid Purchases (CIT)
Question
The taxpayer asked for clarification: under Circular 20/2026/TT-BTC Article 3(13)(c), does 'not yet paid' at the time of expense recognition mean payment deadline under the contract has not arrived, or that no actual payment has been made?
Legal References Cited
- Decree 320/2025/ND-CP dated 15/12/2025, Article 9(1)(c3)
- Circular 20/2026/TT-BTC dated 12/3/2026, Article 3(13)(c)
Core Rules
For single purchases of goods/services worth VND 5 million or more, unpaid at the time of expense recognition:
- May be recorded as a deductible expense if supported by: a purchase contract + a goods/service handover record
- When payment is eventually made: a non-cash payment voucher is required
Consequence of cash payment:
- The company must file a downward expense adjustment in the tax period in which the cash payment occurs
- This applies even if the tax authority has already issued an audit or inspection decision for that period
Practical Notes for Businesses
- 'Not yet paid' = actual payment not yet made (not merely that the contractual due date has not arrived)
- Always retain non-cash payment vouchers when making eventual payment
- If cash payment is made: file corrective declarations in the same period
- Contact the direct managing tax authority for case-specific guidance