Invoice Timing for Wood Veneer Processing Services — Does Not Qualify for Periodic Reconciliation Deferral
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The Ho Chi Minh City Tax Department responded to Hang Thang Co., Ltd. on the timing of invoice issuance for wood veneer lamination processing services. Under clause 6, Article 1 of Decree 70/2025/NĐ-CP amending Article 9 of Decree 123/2020/NĐ-CP, the invoice must be issued **at the time the service is completed**, regardless of whether payment has been received. The Tax Department determined that wood veneer lamination processing services do **not fall** within the list of services permitted to defer invoicing until after data reconciliation (provided under point a, clause 4, Article 9 of Decree 70/2025/NĐ-CP, which covers only aviation support, electricity, water, telecommunications, logistics, banking services, etc.). The company therefore cannot apply the post-reconciliation invoicing mechanism and must issue invoices at service completion.
Tax Q&A: Invoice Timing for Wood Veneer Processing Services
Responding authority: Ho Chi Minh City Tax Department (question code: 201225-4)
Requesting entity: Hang Thang Co., Ltd. (industry: wood veneer lamination processing on MDF, particle board, and finger-jointed panels)
Date: 24 March 2026
Issue Raised
The company asked whether its veneer lamination processing services (high volume, frequent returns) qualify for the post-reconciliation invoicing mechanism under clause 4, Article 9 of Decree 123/2020/NĐ-CP.
Legal Basis
Decree 70/2025/NĐ-CP dated 20 March 2025 amending Decree 123/2020/NĐ-CP:
Clause 2, Article 9 (amended):
Invoices for services must be issued at the time the service is completed (including services provided to foreign organisations and individuals), regardless of whether payment has been received. Where payment is collected before or during service provision, the invoice must be issued at the time of payment collection (excluding deposits or advances for accounting, auditing, financial/tax advisory, valuation, engineering design, construction supervision, and investment project preparation services).
Point a, clause 4, Article 9 (amended) — services eligible for post-reconciliation invoicing (by the 7th of the following month):
Covers: aviation ground support, jet fuel supply, electricity distribution (except point h cases), railway support services, water, cable TV, TV advertising, e-commerce, postal and courier, telecommunications (including value-added telecom), logistics, IT services (except point b cases), banking services (except lending), international money transfers, securities, online lottery, toll road collection between investors and collectors, and other cases as guided by the Minister of Finance.
Tax Authority Conclusion
- Processing service invoices must be issued at the time the service is completed, regardless of payment receipt
- Wood veneer lamination processing does not fall within the post-reconciliation invoicing list under Decree 70/2025/NĐ-CP
- The company must self-assess based on its actual circumstances and comply accordingly