Ministry of Finance answers on how to calculate tax on retail invoices under 5 million VND

On the Government Portal, reader T.N reflected: During the month, company employees bought goods and services from many units, each invoice was under 5 million VND.

At the end of the month, employees merge these invoices into a payment request, with a total value exceeding 5 million VND, and the company pays in cash to employees.

Ms. T.N asked: Are the above expenses deductible when determining corporate income taxable income?

Regarding this issue, the Ministry of Finance has the following opinions:

Point c, Clause 1, Article 9 of Decree No. 320/2025/ND-CP detailing a number of articles and measures to organize and guide the implementation of the Law on Corporate Income Tax stipulates:

Article 9. Expenditures deducted when determining taxable income

1. Excluding non-deductible expenses specified in Article 10 of this Decree, enterprises are entitled to deduct expenses when determining taxable income if they meet the conditions in points a, b and c below:

... c) Non-cash payment vouchers for cases of purchasing goods, services and other payments each time with a value of 05 million VND or more. Non-cash payment vouchers shall be implemented in accordance with the provisions of legal documents on value-added tax;

... c2) In case the enterprise incurs expenses authorized/assigned by the enterprise to employees directly buying goods and services to serve the enterprise's production and business activities from 05 million VND or more, and these expenses are paid by employees using non-cash payment services, they are included in the deductible expenses if they meet the following conditions: Having invoices and documents according to the provisions of law on accounting, invoices and documents and financial regulations or internal regulations or decisions of the enterprise stipulating the authorization or permission for employees to pay for purchased goods and services to serve the enterprise's production and business activities and this expense is then repaid by the enterprise to employees".

According to point c, clause 13, Article 3 of Circular No. 20/2026/TT-BTC detailing a number of articles of the Law on Corporate Income Tax and Decree No. 320/2025/ND-CP of the Government detailing a number of articles and measures to organize and guide the implementation of the Law on Corporate Income Tax, it is stipulated:

Article 3. The dossier of the expense is included in the deductible expense specified in points b and c, clause 1, Article 9 of the Law on Corporate Income Tax.

Expenses included in the deductible expenses specified in points b and c, clause 1, Article 9 of the Law on Corporate Income Tax must have sufficient invoices and documents as prescribed and dossier components. Specific dossier components are as follows:

... 13. Dossiers of some expenses as prescribed in point c, clause 1, Article 9 of the Law on Corporate Income Tax are specified as follows:

... b) For cases where enterprises incur expenses authorized/assigned by enterprises to employees directly buying goods and services to serve the enterprise's production and business activities from 05 million VND or more, and these expenses are paid by employees using non-cash payment services, the dossier includes: Invoices, documents according to the provisions of law on accounting, invoices, documents; financial regulations or internal regulations or decisions of enterprises stipulating the authorization or permission for employees to pay for purchased goods and services to serve the enterprise's production and business activities; non-cash payment documents of employees when purchasing goods and services authorized by enterprises; non-cash payment documents of enterprises repaying employees".

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