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Tax finalization is often when many Vietnamese Amazon sellers first discover a gap in their accounting records: revenue and cash flow are real, but the supporting documents used to substantiate those figures to the tax authority are fragmented, incomplete, or inconsistent. Orders are recorded in Seller Central, funds pass through an intermediary payment wallet before reaching the bank in periodic disbursements, while goods are customs-cleared in batches before being sent to Amazon's fulfillment service warehouses (Fulfillment by Amazon - FBA).
In Vietnam, effective July 1, 2026, Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC officially came into force, introducing specific regulations on electronic commercial invoices for export activities. For Amazon sellers, tax finalization documents are no longer a set of records to be assembled only at year-end; They need to be prepared in full for each transaction onward. The checklist below organizes the four groups of documents sellers should maintain and how to structure the records, so they are ready for explanation and review.
1. Why tax finalization documentation is a weak point for Vietnamese Amazon sellers
Unlike domestic sales, an Amazon transaction typically passes through multiple intermediaries before the funds reach the company's account. Amazon records orders in foreign currency, deducts selling fees, FBA fees, and advertising fees, then remits the net amount according to its periodic settlement cycle. The funds may then pass through an intermediary payment wallet before reaching the seller's bank account in Vietnam.
As a result, order-level revenue, the amount transferred by Amazon, and the amount actually received by the bank may not match. Meanwhile, the statutory invoice issuance time is linked to the transfer of goods or customs clearance, not to the marketplace payout date. Therefore, if a Vietnamese seller relies only on cash received in the bank account, invoices and tax declarations may fall into different periods or show mismatched values.
If Vietnamese sellers cannot prove the origin of their revenue and the validity of their supporting documents, they face three direct risks: losing the 0% VAT rate on exported goods, having expenses disallowed for corporate income tax purposes, and being assessed back taxes plus late-payment interest and penalties upon a tax audit.
2. Group 1: Output invoices and revenue documents
Output invoices are one of the most important components because they form the starting point of the tax finalization document set. All declared revenue figures need to be reconciled with the corresponding invoices.
2.1 Choose the Right Invoice Type for Your Business Model
Under Clause 3, Article 8 of Decree 254/2026/ND-CP, an electronic commercial invoice (Electronic Commercial Invoice) applies to Vietnamese organizations, household businesses, and individual businesses engaged in exporting goods or providing services abroad that meet the conditions for electronically transmitting commercial invoice data to the tax authority. If these conditions are not met, the exporter may choose to issue an electronic value-added tax invoice or an electronic sales invoice.
Detailed guidance on invoice issuance timing and required invoice information for sales conducted through e-commerce platforms has been compiled by Thu Vien Phap Luat based on Decree 254/2026/ND-CP. Sellers should determine the correct invoice type from the beginning of the reporting period, as this choice directly affects how transactions are declared and reconciled at the end of the period.
2.2 Determine the correct invoice issuance time
Clause 1, Article 9 of Decree 254/2026/ND-CP sets out the invoice issuance time for different types of goods. In Vietnam, for goods in general, the invoice issuance time is the time ownership or the right to use the goods is transferred to the buyer, regardless of whether payment has been received. For exported goods, the Vietnamese seller determines the invoice issuance time, but it must be no later than the next working day following the date the goods are customs-cleared.
Under the FBA model, goods are often exported in batches and sent to warehouses before orders are placed by end customers. As a result, the customs-clearance date and the sale date may be several weeks apart. The method for determining the invoice issuance time in this case should be agreed with a tax specialist from the outset to avoid errors in the invoicing process. Regardless of the method applied, the records should still retain both reference points in full: the customs declaration number together with the warehouse shipment identifier (Shipment ID), and the outbound sales order data.
2.3 Check the mandatory information on the invoice
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The seller's name, address, and tax identification number must match the enterprise registration certificate or tax identification notice.
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Transactions arising in foreign currency are recorded in the original currency and must also show the exchange rate used to convert the amount into Vietnamese dong in accordance with regulations.
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The goods must be described in Vietnamese with details for each category; if a foreign-language description is also needed, it should be placed in parentheses or directly below the Vietnamese line.
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For electronic commercial invoices, the buyer's personal identification number and digital signature are not mandatory.
2.4 Handle invoice errors under Circular 91/2026/TT-BTC
Under Clause 1, Article 10 of Circular 91/2026/TT-BTC, if an invoice contains an error only in the buyer's name, address, or amount in words, but the tax identification number, amount, tax rate, tax amount, and goods are correct, the seller notifies the buyer and submits a Notice of Incorrectly Issued Electronic Invoice (Form No. 04/SS-HDDT) to the tax authority; the invoice does not need to be reissued. Errors affecting value or tax, however, must be handled through an adjustment invoice or replacement invoice. In particular, all error notices should be retained together with the original invoice so the documentation remains continuous for tax finalization.
3. Group 2: Transaction statements and payment documents
For marketplace transactions, an invoice only proves that the seller made a sale. To demonstrate that the corresponding funds were actually transferred to the account, the seller also needs payment documents. For Vietnamese Amazon sellers, this means a three-layer document trail that must be reconciled and matched:
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Amazon Settlement Report: shows order-level revenue, fees, refunds, and the net amount transferred in each settlement period.
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Intermediary payment wallet statement: shows the amount received from Amazon, withdrawal fees, and the exchange rate applied when transferring funds to Vietnam.
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Bank Statement: shows the amount in foreign currency or Vietnamese dong actually received in the company's bank account.
This document trail is particularly important because non-cash payment documentation is one of the mandatory conditions for applying the 0% tax rate to exported goods. Any differences across the three layers, including marketplace fees, transfer fees, and foreign-exchange differences, need to be explained with specific figures rather than left as an unidentified amount in the accounting records.
In practice, this is often the most time-consuming part of preparing Vietnamese tax finalization documents because each settlement period may contain hundreds or thousands of transaction lines that must be reconciled manually if no supporting tool is used.
4. Group 3: Export supporting documents for Goods Shipped from Vietnam
For goods exported through Amazon or other foreign e-commerce marketplaces, businesses must meet specific documentation requirements under Clause 1, Article 28 of Decree No. 181/2025/ND-CP, which provides guidance on the Value Added Tax (VAT) Law, in addition to the general VAT requirements. In particular, a customs declaration confirming that goods have left Vietnam is not sufficient on its own. Businesses must also maintain supporting documents proving that the goods have been sold and delivered to buyers overseas.
Under the Fulfillment by Amazon (FBA) model, the date goods leave Vietnam and the date they are actually purchased by end customers may differ. Businesses should therefore track two separate milestones:
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Export shipment date: When goods clear customs and are shipped to Amazon's fulfillment warehouses.
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Sales date: When end customers place orders and the goods are delivered from Amazon's warehouses.
The deadline for issuing invoices for exported goods is governed by Article 9 of Decree No. 254/2026/ND-CP. At the same time, to demonstrate compliance with tax requirements for goods exported through foreign e-commerce marketplaces, Vietnamese businesses must retain documentation proving that the goods have been sold and delivered to overseas buyers, as required under Clause 1, Article 28 of Decree No. 181/2025/ND-CP. A customs declaration issued when goods are shipped to an overseas warehouse does not, by itself, replace the supporting documents required to substantiate subsequent sales transactions.
Under the Fulfillment by Merchant (FBM) model, goods are typically shipped from Vietnam after customers place their orders, meaning the export and sales dates are generally closer together. Nevertheless, businesses must still retain both export documentation and the corresponding order and delivery records for each transaction.
To facilitate reconciliation, sellers should also retain shipping documents, packing lists, commercial invoices, Amazon warehouse receiving confirmations (for FBA), as well as order reports and payment reports exported from Seller Central.
5. Group 4: Export documents for FBA and FBM Models
Vietnamese business expenses such as inventory purchases, Amazon fees, or shipping charges are deductible for income tax purposes only when supported by valid documents. Expense documentation is therefore an essential part of the tax finalization file. For Amazon sellers, expense documents arise from two sources: domestic suppliers and overseas platforms.
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Domestic input invoices: goods, raw materials, packaging, domestic transportation, and logistics services.
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Amazon invoices and fee reports: selling fees (Referral Fee), FBA fees, storage fees, and advertising fees; the figures should be reconcilable to the settlement report.
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Other overseas service documents: software, keyword research tools, outsourced design services, together with the corresponding payment documents.
Note: under Decree 254/2026/ND-CP, an invoice without buyer information or stating “Sold to consumer” is not valid for recording expenses or tax finalization. Vietnamese sellers should ask suppliers to include the company's full name, address, and tax identification number at the time of purchase rather than waiting until year-end to review the documents.
6. Retaining seller documents and tax records
In addition to preparing a complete set of documents, Vietnamese sellers also need to organize their records so they can be retrieved when required. Under the 2015 Law on Accounting and Decree 174/2016/ND-CP, accounting documents used directly for bookkeeping and financial statement preparation must be retained for at least 10 years. Because the tax authority may inspect multiple periods at the same time, tax finalization records from prior years are just as important as those from the current year.
6.1 Record-Keeping Principles
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Organize by period and channel: use one folder per month or quarter, with separate folders for each Amazon marketplace (United States, Europe, Japan, etc.) and each receiving account.
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Cross-link records: each shipment should be linked to the corresponding customs declaration, invoice, settlement report, and bank transaction.
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Retain the original electronic file: electronic invoices should be stored in their original data format (XML), not only as display PDFs.
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Download reports periodically: reports from Seller Central and intermediary payment wallets should be downloaded monthly rather than relying on the platform's display-retention period.
6.2 Summary checklist
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Document group
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Required documents
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Legal basis / purpose
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Output invoices
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Electronic commercial invoice or electronic value-added tax invoice; error notice Form No. 04/SS-HDDT
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Payments
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Amazon Settlement Report, intermediary wallet statement, bank statement
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Condition for the 0% tax rate; revenue reconciliation
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Exports
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Contract with Amazon or the platform manager; customs declaration; bill of lading; Packing List; Amazon inbound receipt (for FBA); evidence of online orders and sales; invoice; non-cash payment records; clause or record of Amazon collecting payment on the seller’s behalf; proof of delivery to buyers abroad.
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Article 18, Decree 181/2025/ND-CP
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Expenses
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Input invoices, Amazon fee reports, overseas service documents
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Deductible expenses for income tax purposes
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Record retention
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Original electronic files; cross-linking by shipment and period
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2015 Law on Accounting; at least 10 years
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The table above can be used as a review list for Vietnamese seller tax records before each tax finalization period: any document group that remains incomplete represents a risk area that should be addressed in advance.
Sliner Standardizes Tax Finalization Records for E-commerce Sellers
Tax finalization documents for Amazon sellers cannot be reconstructed only at year-end. They need to be built and maintained from each shipment, each invoice, and each settlement period. When all four document groups reconcile with one another, tax finalization becomes a reconciliation exercise rather than a race to explain discrepancies.
Sliner advises cross-border sellers on identifying the documentation required for their actual business model, from handling goods sent to FBA warehouses to meeting the conditions for the 0% tax rate. On the operational side, Genbook - an accounting and reconciliation platform for cross-border e-commerce sellers - automatically reconciles Amazon settlement reports, intermediary wallet transactions, and bank statements, helping businesses maintain a consistent tax finalization document set for each period.
Learn more about Genbook accounting software, the Accounting Automation solution, or contact Sliner for a review of your records before the tax finalization period.
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