Guidance on Recording Volume-Based Trade Discount Adjustment Invoices (Decree 254/2026/ND-CP, Circular 91/2026/TT-BTC)

Business's Question

A company applies an end-of-period trade discount policy based on the sales volume of each product line, and issues discount invoices together with a detailed listing of the sales invoices generated during the month. Citing Decree 254/2026/ND-CP, the company asked the Ministry of Finance to clarify three points:

1. Must the listing attached to a volume-based discount invoice show full details (invoice number/serial/date, item name, quantity, unit price, amount, VAT rate, VAT amount) for each invoice, or is it enough to show basic information (invoice number/serial/date, item name, sales volume per invoice, total discount amount, and adjusted VAT)?
2. May a discount invoice record the discount value and VAT as a negative (-) figure?
3. Is the description line «Trade discount for month XX/2026 (with attached sales invoice listing no... dated... month XX 2026)» compliant with current regulations?

Legal Basis Cited in the Answer

• Decree No. 254/2026/ND-CP dated June 30, 2026, issued by the Government, detailing certain articles and implementing measures of Tax Administration Law No. 108/2025/QH15 on e-invoices and e-documents. The Appendix on invoice content, clause 5, requires an invoice to show the name, unit, quantity, and unit price of goods/services; the amount before VAT; the VAT rate; total VAT by each rate; total VAT; and total payment amount including VAT. Point dd of this clause states that when a business applies a trade discount or promotion, the discount or promotion must be clearly shown on the invoice, and the VAT taxable value (amount before VAT) in such cases follows VAT law.
• Circular No. 91/2026/TT-BTC dated June 30, 2026, issued by the Ministry of Finance, guiding certain articles of the Tax Administration Law and Decree 254/2026/ND-CP on e-invoices and e-documents. Clauses 5 and 6 of Article 10 (Handling of issued e-invoices) provide:
  • Point b, clause 5: where a trade discount is based on quantity or sales revenue, the discount amount for goods/services already sold is adjusted on the sales invoice of the final purchase or a subsequent period, provided the discount does not exceed the value of goods/services shown on that invoice; alternatively, an adjustment invoice may be issued together with a listing of the invoice numbers to be adjusted, the adjustment amount, and the adjusted tax. The listing must be kept at the business and produced on request by the tax authority or a competent state agency.
  • Point c, clause 6: for the value on an adjustment invoice, an increase must be recorded as a positive figure and a decrease as a negative figure, matching the actual adjustment.

Conclusion and Guidance

The tax authority directs the company to apply the cited regulations to its actual circumstances. This confirms that a downward adjustment invoice for a trade discount may record a negative figure (per Point c, clause 6, Article 10 of Circular 91/2026/TT-BTC), directly answering the company's second question. On the listing content, the regulation only requires the listing to specify «the invoice numbers to be adjusted, the adjustment amount, and the adjusted tax» - it does not itemize individual line items such as unit price or VAT rate per invoice line; the company should compare this against its own actual situation to determine the appropriate level of detail.

For further issues, the company is directed to contact the Ho Chi Minh City Tax Sub-Department No. 12 - Business Support and Management Team No. 3, phone 028 371 06363, address 282A Nguyen Anh Thu Street, Tan Thoi Hiep Ward, Ho Chi Minh City.

Note: the original answer does not directly state the correct wording for the invoice description line (the company's third question); the company should compare its own wording against the cited regulations above or contact the tax authority directly for specific guidance.