Vietnam E-Invoice Timing for Construction and Installation: At Acceptance, Not on Payment (Official Letter 8091/QNG-QLDN1)

Updated: October 2026

Download the full text of Official Letter No. 8091/QNG-QLDN1 dated 6 October 2026 of the Quang Ngai Provincial Tax Department here (PDF, Vietnamese).

For construction and installation contracts, the most common question accountants ask is: should the invoice be issued when an advance is received, when a progress payment is made, or at acceptance? The answer differs from the rule for ordinary services, and confusing the two is one of the most frequent e-invoice errors in Vietnam.

On 6 October 2026, the Quang Ngai Provincial Tax Department issued Official Letter No. 8091/QNG-QLDN1 to Freetex Group (Vietnam) Co., Ltd. (in reply to its letter No. 03/2026-FT of 1 October 2026) on invoice timing for construction and installation, based on Article 9 of Decree No. 254/2026/ND-CP dated 30 June 2026.

At a glance

1. What Official Letter 8091/QNG-QLDN1 says

The Quang Ngai Tax Department quotes two provisions of Article 9 of Decree No. 254/2026/ND-CP:

Article 9.2: the invoice for services is issued when the service is completed (including services provided to foreign organisations and individuals), whether or not payment has been received. Where the provider collects money before or during the provision of the service, the invoice is issued when the money is collected (excluding deposits under the Civil Code to secure performance of the service contract).

Article 9.4(c): for construction and installation, the invoice is issued at the time of acceptance and handover of the works, work items or completed construction and installation volumes, whether or not payment has been received.

On that basis, the department confirms the principle: for construction and installation, the invoice is issued at acceptance and handover of the works, work items or completed volumes, whether or not payment has been received, under Article 9.4(c) of Decree No. 254/2026/ND-CP.

2. The key point: construction does not follow the “invoice on prepayment” rule

For ordinary services, Article 9.2 requires an invoice as soon as a prepayment is collected. Article 9.4, however, sets specific rules for “certain specific cases”, including construction and installation. Because a specific rule exists, the invoicing trigger for construction and installation is acceptance and handover, not the receipt of money.

In practice:

• Advance payments under a construction contract: on the reading that Article 9.4(c) governs, receiving an advance does not by itself trigger an invoice; the invoice is issued when volumes are accepted and handed over. The letter gives guidance “in principle” and does not address advances specifically, so businesses with unusual arrangements should confirm with their tax office.
• Accepted but not yet paid: the invoice must still be issued at acceptance. Non-payment is not a reason to defer the invoice.
• Staged acceptance: each acceptance and handover of completed volumes is an invoicing point for that volume.

3. Worked example

Contractor A signs a VND 10 billion (excluding VAT) contract to build a factory for a foreign-invested company in an industrial park:

• July 2026: the owner pays a 30% advance (VND 3 billion).
• September 2026: foundations and structure are accepted, with completed volume worth VND 4 billion; the owner has not yet paid.
• December 2026: final acceptance and handover of the whole works.

→ July: the advance is received; not an invoicing point under Article 9.4(c).
→ September: invoice VND 4 billion for the accepted volume, even though payment has not been received.
→ December: invoice the remaining VND 6 billion at acceptance and handover.

If the same contract were an ordinary consulting service rather than construction or installation, the July advance would be an invoicing point under Article 9.2, unless it were a deposit under the Civil Code.

4. Practical notes

• The acceptance record is the decisive document. The invoice date should match the date of acceptance and handover. Invoicing earlier or later than acceptance may be treated as issuing the invoice at the wrong time.
• Separate construction/installation from services. Mixed contracts (equipment supply with installation, design with build) should identify which part is construction or installation so the correct rule is applied.
• A deposit is not a prepayment. For services, a Civil Code deposit securing performance does not trigger an invoice; a prepayment does. Contracts should state clearly what each payment is.
• For foreign-invested owners: when building factories or offices, check the contractor’s invoice dates against acceptance records before claiming input VAT and capitalising costs, to avoid the risk of invoices issued at the wrong time.
• Link progress payments to acceptance. Aligning payment milestones with acceptance makes invoice dates and payment dates coincide, reducing mismatches between revenue, invoices and cash flow.

TrustlineAX helps foreign-invested companies review construction contracts, invoicing processes and VAT filings for investment projects. Contact TrustlineAX for advice.

Disclaimer

This article is based on the full text of Official Letter No. 8091/QNG-QLDN1 dated 6 October 2026 of the Quang Ngai Provincial Tax Department to Freetex Group (Vietnam) Co., Ltd., and the provisions it quotes:

• Article 9.2 and Article 9.4(c) of Decree No. 254/2026/ND-CP dated 30 June 2026.

Scope notes:

1. The letter replies to one specific company, gives guidance “in principle”, and is not a legal normative document.
2. The letter does not address advance payments specifically; the discussion of advances in section 2 and the example in section 3 reflect TrustlineAX’s reading of Article 9.4(c) of Decree No. 254/2026/ND-CP.
3. The timing of VAT liability, revenue recognition for CIT and penalties for invoice violations are outside the scope of this article.

This article is for reference only, does not replace the original legal texts and does not constitute advice on any specific case. Please check the regulations in force at the time of application and consult an adviser before making decisions.

TrustlineAX — Tax, accounting and compliance advisory for foreign-invested enterprises in Vietnam.