VAT Invoice Guidance for Zero-Payment Export Sample Goods
RegHub explainer by New MarketerLast updated:
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 Da Nang Tax Department responded to OBE Vietnam Co., Ltd. on issuing VAT invoices for export sample goods with no payment. Under Decree 320/2025/ND-CP and Circular 20/2026/TT-BTC, export samples without bank payment documents do not meet the conditions for the 0% VAT rate. The tax authority determined that goods exported without charge (no bank payment evidence) fall under the VAT-exempt category per Article 5 of the VAT Law, rather than the 0% taxable category. The company may therefore issue a VAT invoice marked 'Not subject to VAT' for these sample shipments. For case-specific guidance, the enterprise should contact the Da Nang Tax Department directly with actual documentation.
VAT Invoice Guidance for Zero-Payment Export Sample Goods
Issuing Authority: Da Nang Tax Department
Inquiring Entity: OBE Vietnam Co., Ltd. (Tam Thang 2 Industrial Zone, Da Nang)
Situation
The company exports product samples under customs declaration type E62 (export of manufactured goods) to foreign customers without generating any bank payment. Complete documentation exists (customs declaration, contract, bill of lading, commercial invoice, packing list) but no bank payment evidence.
Legal Basis
- Article 4, Decree 320/2025/ND-CP: Conditions for 0% VAT on exported goods require bank payment documentation.
- Article 5(1), VAT Law: Goods with no payment transaction fall under the VAT-exempt category.
- Circular 20/2026/TT-BTC: Invoice and revenue guidance for tax purposes.
Guidance
Because the exported samples generate no bank payment, the 0% VAT rate does not apply. Instead, the company may issue a VAT invoice marked 'Not subject to VAT' under the VAT-exempt goods provisions.
The enterprise must retain full documentation (customs declarations, contracts, shipping documents) to evidence the sample-goods purpose.