Important notes on the scope of non-cash payments under decree No. 320/2025/NĐ-CP

Decree No. 320/2025/NĐ-CP, effective from 15 December 2025, introduces new regulations aimed at enhancing transparency in financial transactions. In addition to lowering the payment threshold to VND 5 million, enterprises should pay particular attention to the scope of application of this regulation, especially with respect to “other payments,” in order to ensure compliance and safeguard their rights when determining deductible expenses.

Detailed contents:

New regulation: Beyond “purchase of goods and services”: Pursuant to Point c, Clause 1, Article 9 of Decree No. 320/2025/NĐ-CP, the conditions for deductible expenses are stipulated as follows:

“Expenses must be supported by non-cash payment documents in cases of purchases of goods and services and other payments, where the value of each payment is VND 5 million or more.
Non-cash payment documents shall be implemented in accordance with the regulations of tax laws on value-added tax.”

Previously, enterprises generally assumed that the requirement for non-cash payments applied only to transactions involving the purchase of goods and services with invoices issued in accordance with regulations. However, the inclusion of the phrase “other payments” has blurred this distinction, reflecting a broader regulatory approach toward all cash outflows of enterprises.

Under the principle of prudence, expenses that do not arise from ordinary purchases of goods or services—such as contractual compensation, financial support payments, financial expenses, or other similar expenditures—with a value of VND 5 million or more are also considered within the scope of this regulation.

Practical recommendations

While awaiting detailed guidance from forthcoming Circulars and implementing documents issued by the competent authorities, to minimize risks related to deductible expenses and facilitate future explanations and audits, the Accounting and Finance Departments are advised to consider the following measures:

• Implement non-cash payment methods for all expenditures of VND 5 million or more, including expenses other than purchases of goods and services.
• Review and update internal payment procedures, and adjust cash payment limits at the cash fund in line with the new regulations.
• Closely monitor and itemize cash expenditures, particularly in cases where the total payment value reaches VND 5 million or more.
• For transactions with individuals, prioritize bank transfers to ensure transparency and full compliance with documentary requirements under Decree No. 320.

Contact information

Mr. Nguyen Bao Anh - Deputy General Director in charge of Tax, Transfer Pricing & Outsourcing Services

Email: anh.nb@a-c.com.vn