Q&A: Invoice issuance timing for labour supply services
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Dong Nai Tax Department No. 10 clarifies: under Decree 70/2025/ND-CP amending Decree 123/2020/ND-CP, the invoice issue date for services is the date the service is completed (regardless of whether payment has been received), or the date the invoice is issued if issued before service completion or before payment. Labour supply services are not among the exceptions listed in Decree 70/2025/ND-CP. Therefore, if the company determines that service completion occurred on the date the review ended and the handover document was signed (8 April 2026), and issues the invoice on the same date, the invoice timing complies with regulations, provided that date is indeed when the service was completed.
Background
Labour supply company Win Win provided services from 2 March to 31 March 2026. A data review continued until 8 April 2026, and the company issued an invoice on 8 April 2026. The company asks whether this invoice date is compliant.
Response from Dong Nai Tax Department No. 10
Under Article 1(4)(a) of Decree 70/2025/ND-CP dated 24 March 2025, which amends Article 9(4) of Decree 123/2020/ND-CP:
- The invoice date for services is the date on which service delivery is completed, regardless of whether payment has been received.
- If the invoice is issued before service completion or before payment, the invoice date is whichever occurs first.
Decree 70/2025/ND-CP lists specific services subject to different rules (electricity, water, telecommunications, construction, etc.); labour supply services are not among these exceptions.
Conclusion:
- If the company determines that service completion occurred on 8 April 2026 (end of the data review period and signing of the handover document), issuing the invoice on that date complies with regulations.
Applicable Regulations
- Decree 70/2025/ND-CP dated 24 March 2025 (amending Decree 123/2020/ND-CP on invoices and documents).
- Article 9(4) of Decree 123/2020/ND-CP dated 19 October 2020.