The same export shipment, the same set of documents — yet value added tax and corporate income tax do not recognise the revenue on the same date. This is not a bookkeeping error. It is the direct consequence of two separate bodies of legislation.
The practical effect is concrete: total revenue across a year’s VAT returns may not match the revenue reported on the CIT finalisation return for that same year. This article sets out the legal basis for each date, identifies where they diverge, and works through specific scenarios.
In short: one follows customs clearance, the other follows transfer of ownership
| VAT — exported goods | CIT — exported goods | |
|---|---|---|
| Determination point | Date of customs clearance — set by the seller, at the latest the following working day | Date of transfer of ownership under the export contract |
| Legal basis | Article 15 of Decree No. 181/2025/ND-CP | Point a, clause 1, Article 5 of Circular No. 20/2026/TT-BTC |
Where the two dates fall in different tax periods, the difference between VAT revenue and CIT revenue is correct and compliant. The company’s task is to be able to explain that difference by reference to a specific customs declaration. The sections below analyse each date and work through practical scenarios.
1. Why one export shipment has two tax dates
Both taxes start from a similar general rule for sales of goods, and both carve out exported goods as a special case — but they carve in opposite directions.
The VAT chain: Article 8 of Law on VAT No. 48/2024/QH15 sets the VAT determination point for goods as the transfer of ownership or right of use, or the invoice date. However, point a, clause 2 of that same Article separates out exported and imported goods and delegates the detail to the Government, which legislated at Article 15 of Decree No. 181/2025/ND-CP.
The CIT chain: Article 8 of Law on CIT No. 67/2025/QH15 defines revenue as all proceeds from sales, processing and services, including subsidies and surcharges, regardless of whether payment has been received. Clause 2 of Article 8 of Decree No. 320/2025/ND-CP sets the general rule — transfer of ownership for goods, completion (or partial completion) for services — and the Ministry of Finance legislated the detail at Article 5 of Circular No. 20/2026/TT-BTC.
The crux: VAT anchors directly to the customs procedure and disregards the contract. CIT anchors to the contract, falling back to customs only where the contract yields no ascertainable date. The two instruments draw on the same facts but rank them in reverse order.
2. The VAT determination point for exported goods
Article 15 of Decree No. 181/2025/ND-CP provides that for exported goods, the VAT determination point is set by the seller, but no later than the working day following the date the goods are cleared through customs.
There are two layers here. First, a right of self-determination: the seller chooses the point. Second, a hard ceiling: that choice cannot fall later than the working day after clearance.
In practice, for most shipments the VAT date is the clearance date or the next working day. The following do not shift it:
- Delivery terms in the sales contract (Incoterms);
- Sailing date, bill of lading date, or the date the buyer physically receives the goods;
- The date payment is received from the overseas counterparty.
3. The CIT revenue recognition point for exported goods
Point a, clause 1, Article 5 of Circular No. 20/2026/TT-BTC provides that for exported goods, the CIT revenue date is the date ownership transfers under the export contract. Where that date cannot be determined, the basis reverts to the rules on establishing exported goods under customs law.
Level one — the contract. The ownership transfer date is fixed by the export contract, and in a standard international sale the delivery terms determine it. The gap between clearance and ownership transfer therefore varies with those terms: on departure-port terms the two dates usually sit close together; on destination terms the transfer date can fall after clearance by exactly the transit time.
Level two — the fallback. Only where the ownership transfer date cannot be determined does customs law apply. This is a technical fallback, not a discretionary option. A company cannot invoke it simply because aligning the two taxes would be more convenient for its books.
On the amount: under point a, clause 1, Article 8 of Decree No. 320/2025/ND-CP, for businesses declaring VAT under the credit method, CIT revenue is revenue exclusive of VAT.
4. Which rule applies to exported services
Article 5 of Circular No. 20/2026/TT-BTC contains no specific rule for exported services. The cases it does address separately in clause 1 are exported goods, air transport, construction and installation (including shipbuilding), and the supply of electricity and water.
Exported services therefore fall under the general rule in point b, clause 2, Article 8 of Decree No. 320/2025/ND-CP: the point of completion, or partial completion, of the service supplied to the buyer.
The phrase “or partial completion” matters. For export service contracts delivered in acceptance phases — common in software, design and consulting — CIT revenue arises as each phase completes. It is not deferred to contract end, and it does not follow the payment schedule.
5. Worked examples
Example 1 — The two dates coincide
Company A exports a USD 200,000 shipment. The contract transfers ownership at the Vietnamese port of loading. Goods clear customs on 10 March 2026 and are loaded the same day.
VAT: the seller determines the point, capped at the working day after 10 March 2026 — revenue falls in the March 2026 or Q1 2026 return. CIT: ownership transfers on 10 March 2026 — revenue falls in the 2026 tax year. No difference arises.
Example 2 — A shipment straddling two tax years
Company B exports a USD 500,000 shipment. The contract transfers ownership on delivery to the buyer’s warehouse overseas. Goods clear customs on 28 December 2026 and reach the buyer’s warehouse on 5 February 2027.
VAT: the USD 500,000 falls in the December 2026 or Q4 2026 return. CIT: the same USD 500,000 falls in the 2027 tax year.
The result: Company B’s total revenue across its 2026 VAT returns exceeds the revenue on its 2026 CIT finalisation return by exactly the converted value of USD 500,000. This difference is correct and compliant.
The risk lies not in the difference itself but in being unable to produce a reconciliation identifying which customs declaration it came from. Without that, a compliant difference looks like omitted revenue.
Example 3 — The contract yields no ownership transfer date
Company C’s export contract states a delivery obligation but contains no provision from which an ownership transfer date can be determined. Goods clear customs on 15 June 2026.
VAT: unchanged — capped at the working day after 15 June 2026. CIT: because the transfer date cannot be determined, the second limb of point a, clause 1, Article 5 of Circular No. 20/2026/TT-BTC applies, reverting to the customs law basis.
The operational lesson: a vaguely drafted contract does not give a company more flexibility. It removes the company’s control over its own explanation, because the CIT date shifts to a different frame of reference.
Example 4 — Exported services accepted in phases
Company D supplies services to an overseas client under a three-phase acceptance contract worth USD 300,000, USD 100,000 per phase. Phases 1 and 2 are accepted during 2026; phase 3 in January 2027. The entire fee is paid in a single settlement after the contract ends.
CIT: revenue arises as each phase completes. USD 200,000 falls in the 2026 tax year and USD 100,000 in 2027 — regardless of the fact that all cash arrives in 2027, consistent with the “regardless of whether payment has been received” principle.
6. Three common errors
First, using the invoice date for exported goods. Article 8 of Law on VAT No. 48/2024/QH15 does mention the invoice date, but as a general rule for goods. Exported goods are carved out by point a, clause 2 of that same Article. On invoice timing for exports, see our e-invoice guide applicable from 1 July 2026.
Second, shifting the tax point to follow collection. Both Article 8 of the VAT Law and Article 8 of the CIT Law state that the position applies regardless of whether payment has been received.
Third, forcing both taxes onto one date to tidy the books. Nothing in Decree No. 320/2025/ND-CP or Circular No. 20/2026/TT-BTC permits substituting the VAT date for the CIT date or vice versa. The correct treatment is to recognise each on its own date and prepare a reconciliation.
7. Review checklist for exporters
- Add these fields to the export register: customs declaration number, clearance date, contractual ownership transfer date, VAT return period, CIT tax year.
- Review separately the shipments clearing in the final month of the tax year — this is the only group that can straddle periods, and it accounts for most of the difference.
- Revisit the standard export contract to ensure it contains a provision from which the ownership transfer date can be determined, avoiding the fallback.
- For multi-phase export service contracts, retain the phase acceptance records supporting CIT revenue recognition. See also our note on handover record requirements.
- Prepare the annual VAT-to-CIT revenue reconciliation at finalisation, explaining each difference by specific customs declaration number.
For an overview of each tax, see our VAT guide and corporate income tax guide for 2026.
This article was prepared by Trustlineax based on Law on CIT No. 67/2025/QH15, Decree No. 320/2025/ND-CP, Decree No. 141/2026/ND-CP, Circular No. 20/2026/TT-BTC, Article 8 of Law on VAT No. 48/2024/QH15 and Article 15 of Decree No. 181/2025/ND-CP. Certain matters fall outside its scope and require separate checking before application to a specific file, including exchange rates for converting foreign-currency revenue, and the conditions and documentation for applying the 0% VAT rate to exported goods and services. It is for information purposes only and does not replace the original legal documents or tailored tax advice for a specific transaction.