To: Ban Mai Engineering and Trading Co., Ltd.
(Address: 19 Le Van Huu Street, Hai Ba Trung District, Hanoi City;
Tax Code: 0100373485)

In response to Official Dispatch No. 2010/CV-BM dated October 20, 2018 of Ban Mai Engineering and Trading Co. Ltd. (Banmaico) on issuance of e-invoices together with manifests, below are opinions of Hanoi Department of Taxation:

- Pursuant to Circular No. 32/2011/TT-BTC dated March 14, 2011 of the Ministry of Finance providing guidelines on creation, issuance and utilization of e-invoices for goods sale and service provisions

+ Clause 1 and Clause 3 of Article 3:

“1. E-invoice refers to a combination of electronic information about goods sale and service provisions that are created, issued, sent, received and stored electronically. An e-invoice must satisfy the requirements specifed in Article 6 of this Circular…

3. A valid e-invoice must simultaneously satisfy all of the following requirements:

a) A reliable assurance regarding the integrity of information displayed on the e-invoice when the information is extracted in the final form that is an e-invoice.

Information integrity is achieved if the information is complete and unchanged apart from changes regarding the form of the invoice during the exchange, storage or display of the e-invoice.

b) The information displayed on the e-invoice can be accessed or used in the complete for if necessary."

+ Artticle 14 elaborates on the implementation:

“2. Apart from specific guidelines provided in this Circular, other contents shall follow provisions specified in Decree No. 51/2010/ND-CP dated May 14, 2010 of the Government and Circular No. 153/2010/TT-BTC dated September 28, 2010 of the Ministry of Finance."

- Pursuant to Clause 1 and 2 Article 19 of Circular No. 39/2014/TT-BTC dated March 31, 2013 elaborating Decree No. 51/2010/ND-CP dated May 14, 2010 and Decree No. 04/2014/ND-CP dated January 17, 2014 of the Government on invoices for goods sale, service provisions and guidelines for invoice issuance when the number of goods and services exceed the number of rows on an invoice:

“During the goods or service sale, if a list of goods or services exceeds the number of row of some invoices, the seller may issue multiple invoices or choose one of the following methods:

1. The seller writes multiple invoices consecutively. Writes “preceeding the next invoice” in the last line listing goods of the previous invoice and writes “following the previous invoice” in the first line listing goods of the next invoice. The invoices must specify all of the goods in order from one invoice to another. The seller and buyer information must be fully specified in the first invoice. Signature and stamp of the seller (if any), signature of the buyer, total price, surcharge, additional fee, trade discount, VAT must be included in the final invoice and cross out the empty section (if any).

If the business facility uses internally-printed invoices, and the invoice creation, printing are done directly by the software and the sold goods and services exceed the number of rows on one invoice, the Provincial Department of Taxation shall consider on a case-by-case basis to allow the business facility to use multiple page invoice if the header of the following invoice page displays: the same invoice reference number as displayed on the first page (automatically provided by the computer system); same name, address and tax code of the buyer and seller as displayed on the first page; same template numbers and symbols as displayed on the first page; together with the note written in Vietnamese without diacritics “tiep theo trang truoc - trang X/Y" (following the previous page - page X/Y) (in which X refers to the page number and Y refers to the total number of pages of that invoice).”

2. The seller can use a manifest to list the types of sold goods and services together with the invoice.

a) Contents in an invoice

The invoice must specify “together with manifest No. ……, ………………(date)". Only specify the general name of the goods in the “goods name” section of the invoice.

Other criteria specified in the invoice shall follow guidelines in Clause 2 Article 16 of this Circular.

b) Contents in a manifest

The seller shall design the manifest to suit the characteristics, models and types of goods but must ensure the following primary information:

+ Seller name, address and tax code

+ Goods name, quantity, unit price, amount. If the seller submits the VAT following the methods of deduction, the manifest must include the criteria of " thuế suất giá trị gia tăng”(VAT rate) and “tiền thuế giá trị gia tăng” (VAT amount). The total amount (exludes the VAT) must match with the amount written on the VAT invoice.

The manifest must specify “together with invoice No. …………… ……………………(date)" and fully bear signatures of the seller and the buyer similar to the invoice.

If there are more than one (01) page of manifest, the manifest pages must be numbered in order and bear the seal of adjoining stamp. The final manifest must include the signatures of both the seller and the buyer similar to the invoice.

The number issued manifests must meet that of the invoce. The manifest must be stored together with the invoice to enable the tax authority to examine and check when necessary.

The seller and the buyer shall manage and store the manifest together with the invoice as per law."

- Pursuant to Official Dispatch No. 820/TCT-DNL dated March 13, 2017 of the General Department of Taxation elaborating e-invoices and providing guidelines for the issuance of e-invoices with number of rows exceeding one page.

Based on the regulations mentioned above, when Banmaico issues an e-invoice for the customer as a result of goods sale, it must compile a full list of sold goods in a manner that ensures the ability to access and use the information in the invoice in the complete form when necessary as specified in Clause 3 Article 3 of Circular No. 32/2011/TT-BTC dated March 14, 2011 of the Ministry of Finance. Banmaico must not create any e-invoices with a physical goods manifest instead of an electronic one.

With respect to the conversion from an electronic invoice to a physical invoice, if the list of sold goods and services exceeds the number of rows in one invoice page, Banmaico shall follow the same regulations on using internally-printed invoices, in which the invoice creation and printing are done directly by the software and the quantity of sold goods and services exceed the number of rows on one invoice. To be specific:

Banmaico may display the invoices on multiple pages if the header of the following invoice page displays: the same invoice reference number as displayed on the first page (automatically generated by the computer system); same name, address and tax code of both the buyer and seller as displayed on the first page; same template numbers and symbols as displayed on the first page; together with the note written in Vietnamese without diacritics “tiep theo trang truoc - trang X/Y" (following the previous page - page X/Y) (in which X refers to the page number and Y refers to the total number of pages of that invoice).

For your reference and compliance./.

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