Giving Tet gifts to hundreds of customers, handing out samples at a trade fair, or giving appreciation gifts to employees on a holiday — in principle, each such “gift or donation” is, in itself, a transaction that requires an invoice, because invoice regulations treat this as a special form of “sale” (without collecting payment). For businesses with hundreds or thousands of small gift transactions in a single campaign, issuing a separate invoice for each one used to be a significant operational burden for the accounting department. From 1 July 2026, Decree No. 254/2026/ND-CP on invoices and documents officially codifies a mechanism allowing businesses to issue a consolidated invoice on a monthly or quarterly basis for this group of transactions. Based on the original text of Decree No. 254/2026/ND-CP, Law on Value-Added Tax No. 48/2024/QH15, and Decree No. 181/2025/ND-CP, this article explains how the new rule applies, its conditions, and the points businesses most often get wrong.
1. Legal basis
- Decree No. 254/2026/ND-CP (dated 30 June 2026) of the Government on invoices and documents, effective from 1 July 2026, replacing Decree No. 123/2020/ND-CP and Decree No. 70/2025/ND-CP in their entirety — Article 4 (principles for issuing invoices), Article 10, and the Appendix “Content of the Invoice” issued with the Decree (Section 5, point a, item a.3).
- Law on Value-Added Tax No. 48/2024/QH15 (Article 7, Clause 1, point c) and Decree No. 181/2025/ND-CP (Article 6) — governing the VAT taxable price for goods/services used for exchange, internal consumption, donation, gifting, and promotion, both effective from 1 July 2025.
- Decree No. 70/2025/ND-CP (amending Decree 123/2020/ND-CP, effective 1 June 2025) — the predecessor regulation, used here as a point of comparison.
2. The unchanged general principle: a gift is still a “transaction” requiring an invoice
Before discussing what is new, it is worth emphasizing a principle that has not changed across successive amendments: under Clause 1, Article 4 of Decree 254/2026/ND-CP, a seller must issue an e-invoice when selling goods or providing services, “including cases where goods or services are used for promotion, advertising, or as samples; goods or services given, donated, exchanged, paid to employees in lieu of wages, or used for internal consumption…”. This wording is essentially unchanged from the earlier Decree 123/2020/ND-CP and Decree 70/2025/ND-CP.
In other words, gifts for customers, Tet gifts for employees, and promotional samples are not exempt from invoicing. What changes from 1 July 2026 is not “whether an invoice must be issued”, but how the invoice is issued — specifically, businesses may now consolidate multiple transactions into a single periodic invoice instead of issuing one for each transaction.
3. What is new: a CONSOLIDATED invoice on a monthly/quarterly basis for promotional goods and gifts/donations
Under Section 5, point a, item a.3 of the Appendix “Content of the Invoice” issued with Decree 254/2026/ND-CP:
“For goods and services used for promotion in accordance with trade law, and goods and services given, donated, or gifted in accordance with the law, businesses may issue a consolidated invoice for transactions arising within a month or quarter, consistent with the enterprise’s or individual’s VAT declaration period.”
3.1. Scope of application
The consolidated invoice mechanism applies to two groups of transactions:
- Promotional goods and services conducted strictly in accordance with trade law (i.e., a promotion program that has been registered or notified to the state trade management authority under the Commercial Law and its guiding documents).
- Goods and services given, donated, or gifted in accordance with the law — for example, customer gifts, Tet gifts, employee anniversary gifts, free samples, sponsorship or charitable donations, etc.
3.2. Mandatory conditions for issuing a consolidated invoice
This is the part businesses need to read most carefully, as Decree 254/2026/ND-CP attaches three binding conditions:
- Complete and accurate reflection: the selling business is responsible for ensuring the consolidated invoice fully and accurately reflects all promotional, gift, and donation transactions arising in the period.
- Retention of a detailed list and related records: the business must keep a detailed list of the promotional/gift/donation goods and services, together with related records (e.g., a gift-giving decision or plan, a list of recipients, a registered promotion program), and provide them to the tax authority upon request.
- The invoice must clearly state “accompanied by list No. …, dated …”, with the accompanying list showing the seller’s name, tax code, and address, the name of the goods/services, quantity, unit price, amount, the date prepared, and the signature of the person who prepared the list.
Failing to meet any of these conditions — particularly the accompanying detailed list — may lead the tax authority to treat the consolidated invoice as not accurately reflecting the true nature of the transactions during an inspection or audit.
4. Compared with the previous rule: Decree 70/2025 had “opened the door” but left the applicable period unclear
This is not the first time the law has allowed consolidation of invoices for promotions and gifts. Decree No. 70/2025/ND-CP (amending Decree 123/2020/ND-CP, effective from 1 June 2025) already provided:
“Where goods or services are promoted in accordance with trade law, or given, donated, or gifted in accordance with the law, a consolidated invoice may be issued for the total value of the promoted, given, donated, or gifted goods, accompanied by a list of such goods.”
In substance, the mechanism for consolidating invoices has existed since mid-2025. However, the earlier rule did not specify the period over which the consolidated invoice should be prepared — by campaign, by day, or by month — leaving many businesses and accountants uncertain in practice, with some choosing the safer route of issuing a separate invoice for each transaction. Decree 254/2026/ND-CP clarifies this point: the consolidated invoice must be prepared for transactions arising within a month or quarter, matching the business’s VAT declaration period — that is, a business that declares VAT monthly consolidates invoices monthly, and one that declares quarterly consolidates quarterly. This is a genuinely meaningful change for large-scale, high-frequency promotion and gift-giving campaigns.
5. Do not confuse a consolidated invoice with a tax exemption: the VAT taxable price of a gift is NOT zero
This is the point businesses most often get wrong, and it carries the biggest tax risk when applying the consolidated invoice mechanism. Being allowed to consolidate invoices (a matter of procedure and form) is entirely different from whether output VAT must be declared and paid (a matter of taxable price). Under Article 7, Clause 1, point c of Law on VAT No. 48/2024/QH15 and Article 6 of Decree No. 181/2025/ND-CP:
- Goods and services given, donated, or gifted: the VAT taxable price is the taxable price of an identical or equivalent good/service at the time the transaction arises — meaning the business must still declare and pay output VAT based on the market value of the gift, even though no payment was collected from the recipient.
- Goods and services used for promotion in proper compliance with trade law (validly registered or notified — e.g., a free item bundled with a purchase, a trial sample, or a prize under a publicly announced lucky-draw program): the taxable price is determined to be zero (0).
- Where a business runs a so-called “promotion” that is not registered or notified in accordance with trade law, the taxable price is still treated as an ordinary gift/donation (i.e., it does not qualify for the zero taxable price).
In other words: being permitted to issue a single consolidated invoice does not mean the gift is not subject to VAT. For gifts and donations that do not fall under a valid promotion program, the business must still determine the correct equivalent market price to calculate output VAT, regardless of whether the invoice is consolidated or issued separately.
6. Illustrative examples
Example 1 — Tet gift baskets for customers (not part of a registered promotion program):
In January 2027, Company A gives 200 Tet gift baskets to loyal customers, each basket having an equivalent market selling price of VND 600,000 (exclusive of 10% VAT). This is an ordinary “gift/donation” activity, not a promotion program registered with the trade management authority.
- VAT taxable price = VND 600,000/basket (based on the selling price of an identical good), not zero.
- Output VAT = 600,000 × 10% × 200 baskets = VND 12,000,000.
- At the end of January 2027, Company A may issue one consolidated invoice for all 200 gift baskets, with a total pre-tax value of VND 120,000,000 and VAT of VND 12,000,000, accompanied by a list of the 200 recipients — instead of having to issue 200 separate invoices.
Example 2 — A “buy 2, get 1 free” promotion registered with the authorities:
Company B runs a “buy 2, get 1 free” promotion that has been validly notified to the Department of Industry and Trade. For the free item, the VAT taxable price is determined to be zero. Company B may still issue a monthly/quarterly consolidated invoice for all the free items given during the period, accompanied by a detailed list, without any additional output VAT arising on the promotional item.
7. When a customer requests a separate invoice
The consolidated invoice mechanism does not remove a recipient’s right to request their own invoice. Decree 254/2026/ND-CP explicitly provides: “Where a customer requests an invoice for an individual transaction, the seller must issue an invoice to the customer in accordance with the regulations.” Businesses should take care to exclude that transaction from the end-of-period consolidated list to avoid duplication or double declaration.
8. What businesses should prepare
- Review gift-giving, promotion, and sampling programs already running or planned from 1 July 2026, and clearly classify each as either a “promotion validly registered under trade law” (zero taxable price) or an ordinary “gift/donation” (still subject to output VAT based on equivalent market price).
- Prepare a standard template for the detailed list/schedule that must accompany each consolidated invoice (recipient name or program, quantity, reference unit price, amount), and retain the related records (gift-giving decision, program plan, promotion notification) needed to explain the invoice during a tax inspection or audit.
- Align the consolidated invoice period with the business’s own VAT declaration period (monthly or quarterly) to avoid discrepancies between the invoice and the tax return.
- Put in place an internal process for handling customer requests for a separate invoice (if any) and correctly excluding that transaction from the end-of-period consolidated invoice.
- For gifts and donations, proactively determine the selling price of an identical or equivalent good/service at the time the transaction arises so that output VAT is calculated correctly, avoiding price assessment or back-tax collection during a tax finalization or audit.
This article was prepared by Trustlineax based on Decree No. 254/2026/ND-CP (Article 4, Article 10, and the Appendix “Content of the Invoice”), Law on Value-Added Tax No. 48/2024/QH15 (Article 7), Decree No. 181/2025/ND-CP (Article 6), and Decree No. 70/2025/ND-CP. The examples are illustrative of general principles only and do not replace the original legal text or specific tax advice for any particular program or transaction.