CIT Deductible Expenses: Employee Purchases on Behalf of Company and Consolidated Payment Rules
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Based on:Nghị định 320/2025/NĐ-CP; Thông tư 20/2026/TT-BTC - 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 clarified that when employees purchase goods or services on behalf of a company, each individual transaction (each invoice) determines whether the non-cash payment requirement applies - not the aggregate reimbursement request. The VND 5 million threshold is assessed per purchase transaction, not per consolidated payment claim. Under Article 9.1(c2) of Decree 320/2025/ND-CP, if the company delegates an employee to purchase goods/services of VND 5 million or more per transaction and the employee pays using a non-cash method, the expense is deductible provided proper invoices and documentation exist and the company reimburses the employee by bank transfer. For individual invoices below VND 5 million, there is no mandatory non-cash payment requirement for that specific transaction. Companies must maintain internal financial regulations clearly authorising employee purchases, supported by the employee's non-cash payment records and the company's bank transfer records for the reimbursement.
CIT Deductible Expenses: Employee Purchases on Company's Behalf
Source: Ministry of Finance response (official portal), 13 April 2026
Question
Employees make multiple purchases during the month from different suppliers, each invoice below VND 5 million. At month-end, invoices are consolidated into one reimbursement request exceeding VND 5 million. If the company pays the employee in cash for the consolidated amount, are these expenses deductible?
Legal Basis
- Article 9.1(c) of Decree 320/2025/ND-CP: Expenses require non-cash payment documentation for individual purchases of VND 5 million or more per transaction.
- Article 9.1(c2) of Decree 320/2025/ND-CP: Where an employee is authorised to purchase on behalf of the company and the transaction is VND 5 million or more, the employee must use non-cash payment; the company must reimburse the employee by non-cash method; proper invoices, authorisation documents, and payment records are required.
- Article 3.13(c) of Circular 20/2026/TT-BTC: Required documentation includes invoices; internal financial regulations or authorisation decision; employee's non-cash payment records; company's non-cash reimbursement records.
Ministry of Finance Conclusion
The VND 5 million threshold applies per individual transaction, not to consolidated reimbursement requests. Companies must assess the non-cash payment requirement on a per-invoice, per-transaction basis.