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ASSET TRANSFERS BETWEEN COMPANY BRANCHES: WHEN MUST AN E-INVOICE BE ISSUED?

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When is an e-invoice required for transferring assets between branches? 01/7/2026

From July 1, 2026, e-invoices are required for transfers of assets between branches that are not subject to VAT, except in cases where such transfers are part of the same economic entity and do not involve the actual handover of goods or services.

According to Clause 2, Article 6 of Decree 123/2020/ND-CP, which has been amended and supplemented, the following conditions must be met:

“The branch’s transfer of assets is considered a transaction subject to VAT, so the asset transfer must be handled in accordance with the provisions of law on VAT, and an e-invoice must be issued by the transferring branch.”

Accordingly, when transferring assets between branches that are subject to VAT, the transferring branch must issue an e-invoice in accordance with the provisions of law.

Therefore, businesses need to clearly determine whether the asset transfer between branches qualifies as a taxable transaction, so that they can apply the correct regulations on e-invoice issuance.

When is the time to issue a VAT invoice for each transaction of a company?

According to Clause 2, Article 6 of Decree No. 254/2026/ND-CP, on the time of issuing electronic VAT invoices, businesses must issue invoices for each transaction of goods or services at the time of completion of the supply, regardless of whether the payment has been made.

Clause 1, Article 9 of Decree No. 254/2026/ND-CP regulates the time of issuing invoices for goods or services, as follows:

“When the supply of goods or services is completed, or when the sales of goods or services are made (regardless of whether the payment has been made), the seller shall issue an invoice to the buyer.”

In addition, Clause 3, Article 9 of Decree No. 254/2026/ND-CP stipulates that businesses operating in the wholesale sector with characteristics of continuous and frequent supply, and having more than one time of delivery, shall issue invoices following the time of each delivery.

Therefore, the time to issue a VAT invoice for goods or services is the time of completion of the supply of goods or services, or the time of each delivery for the continuous supply of goods or services, regardless of whether the payment has been made.

For goods or services subject to multiple deliveries, each delivery shall be invoiced separately at the time of delivery.