Invoice and Tax Treatment for Expired Unused Gift Vouchers
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Based on:Nghị định số 123/2020/NĐ-CP (sửa đổi bởi Nghị định số 70/2025/NĐ-CP) - Ministry of Finance
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Ho Chi Minh City Tax Sub-department 1 (on behalf of the Ministry of Finance) advises on the invoice and VAT treatment for 7 gift vouchers of VND 1 million each that were fully paid by customers but expired unused. Under Article 4(1) of Decree No. 123/2020/ND-CP (as amended by Decree No. 70/2025/ND-CP), sellers must issue invoices when selling goods or providing services. The tax authority advises the business to assess its specific situation against the invoicing rules to determine whether an invoice must be issued for the value of the expired vouchers. The tax authority did not issue a definitive ruling but instructed the business to self-assess based on the nature of the transaction and applicable invoicing principles.
Invoice and VAT Treatment for Expired Gift Vouchers
Responding authority: HCMC Tax Sub-department 1 (Inquiry code: 270226-16) Inquirer: Hoang Thi Thu Trang Date: 6 April 2026
Scenario
- Business issued 8 gift vouchers at VND 1 million each, total VND 8 million
- Customer paid VND 8 million in full before receiving vouchers
- Terms: 'Expired gift cards are deemed used and non-refundable'
- Outcome: 1 voucher used (invoice issued), 7 vouchers expired unused
Questions
- Must the business issue invoices for the 7 expired vouchers?
- If so, should the invoice state 'Gift voucher value forfeited per programme terms'?
Applicable Rule
Article 4(1) of Decree No. 123/2020/ND-CP (as amended by Article 1(3)(a) of Decree No. 70/2025/ND-CP): 'When selling goods or providing services, the seller must issue an invoice to the buyer (including goods and services used for promotions, advertising, samples; goods and services given as gifts, exchanges, or as wages in kind; internal consumption...)'
Tax Authority Guidance
The business must self-assess its specific circumstances against Article 4(1) of Decree 123/2020 (as amended by Decree 70/2025) and act accordingly. The tax authority did not issue a specific ruling.
Practical note: The event of voucher expiry with no refund represents an economic event that generates income/revenue, which may require invoice issuance and VAT declaration.