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Can businesses design their own electronic invoice templates?

Question: 

Recently, we attended an electronic invoice conference organized by TS24 company, following Decree 119/ND-CP and Circular 68/2019/TT-BTC. During the conference, we were informed that if we adopt electronic invoices according to Circular 68/2019/TT-BTC, businesses are only allowed to use up to 05 invoice templates as specified in Circular 68/2019/TT-BTC. Is this information correct? Can businesses design their own electronic invoice templates as they did with paper invoices in the past? 

Answer: 

Based on Article 5 of Decree No. 119/2018/ND-CP dated September 12, 2018, by the Government regarding electronic invoices for the sale of goods and provision of services, electronic invoices include the following types: • Value-added tax invoices; sales invoices; and other types of invoices, including electronic stamps, electronic tickets, electronic cards, electronic receipt vouchers, electronic export and transport vouchers, or other electronically titled documents in accordance with the provisions of Article 3 of Circular No. 68/2019/TT-BTC dated September 30, 2019, by the Ministry of Finance. • However, at present, the Ministry of Finance is drafting a Decree guiding the implementation of electronic invoices in accordance with the provisions of the Law on Tax Administration No. 38/2019/QH14 to replace Decree No. 119/2018/ND-CP for submission to the Prime Minister for approval. Therefore, if the tax authority has not notified the Company to switch to using electronic invoices in accordance with the provisions of Decree No. 119/2018/ND-CP, the Company shall initiate, issue, and use electronic invoices in accordance with the provisions of Decree No. 51/2010/ND-CP and Circular No. 32/2011/TT-BTC by the Ministry of Finance, as specified.

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