VAT invoicing and declaration guidance for self-manufactured tools transferred for internal use in construction companies
RegHub explainer by New MarketerLast updated:
Based on:Nghị định 123/2020/NĐ-CP Điều 4; Nghị định 181/2025/NĐ-CP Điều 6 - Ministry of Finance
This explanation was generated by AI and checked by an automated AI review, not by a human expert. It is not legal, tax or accounting advice and may contain errors. Check the official document before you rely on it.
The Ministry of Finance (through Can Tho City Tax Department) confirmed that self-manufactured tools such as scaffolding frames, diagonal braces, and similar equipment produced by a construction company and transferred to project sites for construction use qualify as internal goods in circulation to continue the production process. Under Clause 1, Article 6 of Decree 181/2025/ND-CP, such goods are excluded from VAT liability. The tax authority confirmed that the company is not required to issue an invoice and is not required to declare or pay VAT on the internal transfer of these self-manufactured tools. Earlier audit positions requiring invoice issuance (even without VAT) were found inconsistent with the applicable regulations.
Background
A construction company self-manufactures tools (scaffolding, bracing, diagonal members) and transfers them to its contracted project sites for construction use. The company asked whether it must issue a VAT invoice and declare VAT.
Legal Basis
- Clause 1, Article 4 of Decree 123/2020/ND-CP: Sellers must issue invoices for goods/services, including internal consumption — except goods in internal circulation to continue the production process.
- Clause 1, Article 6 of Decree 181/2025/ND-CP (effective 01/7/2025): Internal consumption goods exclude goods transferred to internal warehouses, materials, or semi-finished products to continue the production/business process within one business establishment — these are not subject to VAT.
Tax Authority Conclusion
Self-manufactured tools transferred by a construction company to its own contracted project sites qualify as internal goods circulation to continue production:
- No invoice required
- No VAT declaration or payment required
Businesses should verify the applicable rules and contact their managing tax authority for case-specific guidance.