Official Dispatch 7552/CT: Invoice adjustments or replacements required when converting from export processing status

In Official Dispatch No. 7552/CT-QLNT dated October 12, 2026, addressed to the Bac Ninh City Tax Office, the Tax Department provides guidance on handling electronic invoices when an enterprise changes its project objectives from operating as an export processing enterprise to operating as a non-export processing enterprise during investment and construction.

According to Official Dispatch No. 7552/CT-QLNT, where an enterprise holds an Investment Registration Certificate identifying it as an export processing enterprise but changes its project objectives during investment and construction, the suppliers and the enterprise must adjust or replace previously issued electronic invoices.

Invoices must be handled in accordance with Decree No. 70/2025/ND-CP. From July 1, 2026, Circular No. 91/2026/TT-BTC applies.

The legal bases cited by the Tax Department are Clause 13, Article 1 of Decree No. 70/2025/ND-CP, which amends and supplements Decree No. 123/2020/ND-CP regarding the replacement and adjustment of electronic invoices, and Article 10 of Circular No. 91/2026/TT-BTC, which provides guidance on handling electronic invoices.

Official Dispatch 7552/CT

The Official Dispatch also clarifies when an export processing enterprise becomes eligible for investment incentives and tax policies applicable to non-tariff zones. Specifically, an enterprise is entitled to these incentives and policies from the time the investment objective of establishing an export processing enterprise is recorded in its Investment Registration Certificate, amended Investment Registration Certificate, or Certificate of Export Processing Enterprise Registration issued by the competent investment registration authority.

Upon completion of construction and before officially commencing operations, an export processing enterprise must obtain confirmation from the competent customs authority that it meets the customs inspection and supervision conditions prescribed by the laws on export and import duties. If such confirmation is not obtained, the enterprise is not entitled to the tax policies applicable to non-tariff zones.

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