Question:
We are a company engaged in the sale of automobiles, spare parts, and automobile warranties. Providing a warranty for a car to a customer generates many items and spare parts, making the list of goods and services sold longer than a single page of a paper invoice. In this case, we create a detailed list, and when we issue an electronic invoice to the customer, we only state ‘automobile warranty provided according to the attached detailed list.’ Is this correct? If it is incorrect, how should we correct the issuance of electronic invoices with attached detailed lists?
Answer:
Based on Clause 1 and Clause 3 of Article 3 of Circular No. 32/2011/TT-BTC dated March 14, 2011, by the Ministry of Finance, providing guidance on the initiation, issuance, and use of electronic invoices for the sale of goods and provision of services.
In compliance with the guidance in Official Letter No. 2532/TCT-CS dated June 24, 2019, and Official Letter No. 2047/TCT-CS dated May 22, 2019, of the General Department of Taxation on electronic invoices.
Based on the above regulations and guidance:
• An electronic invoice essentially consists of electronic data messages about the sale of goods and provision of services, initiated, created, transmitted, received, stored, and managed electronically. The number of lines can increase depending on the quantity of goods or products on the invoice. When selling goods, the company issues an electronic invoice to the customer, and the company must create a complete list of goods and services sold to ensure that the information contained in the electronic invoice can be accessed and used in full when needed, in accordance with Clause 3 of Article 3 of Circular No. 32/2011/TT-BTC dated March 14, 2011, by the Ministry of Finance.
• If the company issues an electronic invoice that does not display a complete list of goods and services sold but attaches a detailed list for the customer, including goods and services that are not displayed on the electronic invoice, it does not comply with electronic invoice regulations.
• If the company has issued an electronic invoice with an attached detailed list, both the buyer and seller should create a record to withdraw the incorrectly issued invoice and, at the same time, the company should issue a new invoice as a replacement in accordance with the regulations.
