A very practical question for accountants: when a company buys goods or services in a single transaction of VND 5 million or more but has not yet paid at the point the expense is recognised, what documentation is needed for that cost to be deductible for corporate income tax? And specifically: does the handover record — one of the required documents — follow a prescribed template under tax law?
Official Letter No. 17126/DON-QLDN1 dated 8 September 2026 of the Dong Nai City Tax Department answers this directly. Trustlineax summarises it for businesses and finance teams.
1. Legal basis
- Official Letter No. 17126/DON-QLDN1 dated 8 September 2026 of the Dong Nai City Tax Department.
- Article 3 of Circular No. 20/2026/TT-BTC dated 12 March 2026 of the Ministry of Finance — documentation for deductible expenses under points b and c, clause 1, Article 9 of the Law on Corporate Income Tax.
2. Three documents required where payment has not been made
Under point c, clause 13, Article 3 of Circular No. 20/2026/TT-BTC, where goods or services are purchased in a single transaction of VND 5 million or more and the company has not paid by the time the expense is recognised, the cost is deductible provided the company holds a purchase contract, a handover record for the goods or services, and, on payment, non-cash payment documentation.
All three are required together. Missing any one of them can result in the expense being disallowed at CIT finalisation.
3. Is there a prescribed handover record template?
This is the key clarification: current corporate income tax law does not prescribe a template for the handover record.
The tax authority explains that the purpose of the handover record is to serve as factual documentation proving the transaction actually took place. Businesses are therefore directed to consult the Civil Code, the Commercial Law, the Accounting Law and related instruments, and to design a record appropriate to the particular type of goods or services involved.
In other words, a company drafts its own template. There is no standard form issued by the tax authority, and none needs to be waited for. What matters is that the content accurately and fully reflects the substance of the transaction.
4. What the handover record should contain
Because no template is prescribed, the burden of proof sits with the company. A record consisting of a few generic lines will not be persuasive under audit. The following are the minimum contents that give a handover record real evidential value:
| Content | Why it matters |
|---|---|
| Both parties: name, address, tax code | Identifies the correct parties and matches the contract and invoice |
| Number and date of the related contract | Ties the record to the contract as a single coherent file |
| Description of goods or services: name, specification, unit | Proves what was delivered and matches the invoice |
| Quantity and value | Basis for reconciliation against the invoice and the books |
| Date of handover | Determines the period in which the expense is recognised — the most commonly questioned point in an audit |
| Place of handover | Adds credibility, particularly for goods requiring transport |
| Confirmation of the condition of goods or the outcome of services | Shows the transaction was completed, not merely papered |
| Signatures and seals of both parties | Without the supplier’s confirmation the record has no evidential weight |
The table above was compiled by Trustlineax based on general accounting documentation requirements and the evidential purpose described in the official letter. It is not a mandatory list prescribed by law.
For services, the handover record is often titled an “acceptance record” or “record confirming completed work volume”. The title matters less than the content, provided it demonstrates that the service was genuinely delivered.
5. Form of documentation and retention
Under clause 14, Article 3 of Circular No. 20/2026/TT-BTC, documentation supporting a deductible expense must be an original, a certified copy, a copy bearing the company’s seal, or an electronic document compliant with law.
Under clause 15, Article 3, the company is responsible for retaining and producing the full file for inspection, audit and examination purposes.
6. What businesses should watch
- For single transactions of VND 5 million or more left unpaid at recognition, assemble all three documents from the outset rather than scrambling at finalisation.
- Prepare a standard template suited to your goods or services and use it consistently. Drafting a different format each time is how files become inconsistent.
- Note that this VND 5 million threshold applies to CIT deductibility. A separate rule using the same threshold governs non-cash payment documentation for input VAT credit — two different rules at the same figure, easily conflated. See our VAT guide for FDI companies.
- For an overview of deductibility conditions and other changes, see the corporate income tax guide for 2026.
This article was prepared by Trustlineax based on Official Letter No. 17126/DON-QLDN1 dated 8 September 2026 of the Dong Nai City Tax Department and Circular No. 20/2026/TT-BTC dated 12 March 2026 of the Ministry of Finance (clauses 13, 14 and 15 of Article 3). It is for information purposes only and does not replace the original legal documents or tailored tax advice for a specific type of goods or services.