Do free gifts need to be invoiced?
Have. According to current regulations on electronic invoices, the scope of invoicing includes goods and services used for promotions, advertising, samples, gifts, donations, exchanges, payment in lieu of wages for employees, and internal consumption, except in cases where the law stipulates otherwise.
Therefore, businesses should not rely on the fact that they "don't collect payment" to conclude that they don't need to issue invoices.
Before preparing the accounting entry, the accountant should determine which category the transaction falls under:
- Giving, gifting, or presenting to customers or partners.
- Donating goods to workers.
- Promotional goods as defined by commercial law.
- Samples are used for advertising and product demonstrations.
- Free gifts included with the sales promotion.
- Goods used for purposes other than intended are not subject to charge.
All of the above cases may have the characteristic of "the recipient not paying," but the method of determining the taxable value, the documentation, and the handling are not entirely the same.
Goods were shipped but the recipient did not pay.
- Step 1 — Has the merchandise been transferred to another party?If so, proceed to define the purpose of the transfer.
- Step 2 — Does the transaction fall under a promotional program according to commercial law?
- Have: Process according to regulations for promotional items.
- Are not: Further investigation is needed to determine whether these are gifts or donations.
- Step 3 — If it's a gift: Verify the invoice date, recipient information, taxable value, tax rate, and related documentation.
Conclude: We shouldn't start with the question "should we charge or not?", but rather with... business nature.
Latest regulations on issuing invoices for free gifts in 2026.
At the time of updating this article, businesses need to separate the regulations into two groups: Regulations on issuing electronic invoices and regulations on VAT.
Regulations on electronic invoices
From July 1st, 2026, Decree 254/2026/ND-CP will take effect, providing detailed regulations and guidance on the implementation of Law 108/2025/QH15 on Tax Administration regarding electronic invoices and electronic documents. Circular 91/2026/TT-BTC will also take effect on the same day to provide guidance on some related issues.
Therefore, operational guidelines based solely on Decree 123/2020/ND-CP or Decree 70/2025/ND-CP need to be reviewed when applied to transactions arising from July 1, 2026.
Decree 123/2020/ND-CP
Establishing a legal framework for invoices and supporting documents was done in the previous phase.
Decree 70/2025/ND-CP
Amend and supplement certain provisions of the previous regulatory system.
Decree 254/2026/ND-CP
The current regulatory framework for electronic invoices and electronic documents is in effect at the time this article was updated.
Current application: Businesses need to review business activities arising from July 1, 2026, under the new legal framework, instead of simply copying the old guidelines from Decree 70/2025.
Regulations on the basis for calculating VAT
For goods and services used for internal exchange, consumption, gifts, or donations, accountants need to determine the taxable value according to the applicable VAT regulations, reflecting the true nature of the transaction at the time it occurs.
Meanwhile, goods and services used for promotional purposes. in accordance with commercial law regulations There is a separate mechanism for determining the taxable value. Therefore, the "0 VND" mark should not be applied to all cases of gifted goods.
How do gifts differ from promotional items?
This step should be taken before entering data into the invoicing software.
| Major | The decisive question | Bill | Principles for handling tax assessment prices | What the accountant needs to do |
|---|---|---|---|---|
| Ordinary giving, gifting, or presenting. | The item was delivered to the recipient but was not part of a promotional program? | This falls within the scope of invoicing requirements as stipulated by applicable regulations. | Determined according to VAT regulations for gift and donation transactions. | Verify the recipient, delivery time, taxable value, and documentation. |
| Promotion | Does the program comply with commercial law regulations? | Within the scope of invoicing. | Apply the tax mechanism for promotional activities when the conditions are met. | Check the program's format, conditions, and documentation. |
| Discounts in the promotional program | Customers still buy the products but get a discount? | Issue invoices based on actual transactions. | The product will be sold at the discounted price if applicable regulations are met. | Not to be confused with free gifts. |
| Sample | Is the main purpose to allow customers to try the product, advertise it, or introduce it? | It needs to be determined according to current electronic invoice regulations. | It depends on the nature of the business and the applicable conditions. | Check the purpose, program, and related documents. |
Step-by-step guide on how to issue an invoice for free gifts.
- 1Business classification
- 2Determine the time
- 3Check the recipient
- 4Inspect the goods.
- 5Determining the taxable value
- 6Check the tax rate.
- 7Issuance and archiving of records
Step 1: Identify the correct type of transaction.
First, the accountant needs to determine whether the goods are being withdrawn from inventory for general gifts, employee gifts, promotions, samples, or to support another program.
Classification helps determine the correct tax basis, how to determine the taxable value, and the necessary documentation to be kept.
Step 2: Determine the time of invoice issuance.
For goods, the general principle is that the time of invoice issuance is linked to the time of transfer of ownership or the right to use the goods as stipulated in the applicable regulations, rather than waiting until payment is made.
With free gifts, accountants need to keep track of the actual delivery or transfer date.
Step 3: Identify the recipient's information
Invoices must reflect the buyer's or recipient's information as required by applicable regulations and based on existing business data.
For programs with multiple recipients or where recipients provide incomplete information, businesses should not create fake data to fulfill invoices. Current regulations and internal data procedures must be reviewed before issuance.
Step 4: Record the correct goods and quantities.
The item name, unit of measurement, quantity, and related information should accurately reflect the actual goods delivered. Explanations of the gift/donation transaction may be added when necessary for easier record-keeping, but these explanations do not replace the mandatory fields on the invoice.
Step 5: Determine the taxable value.
This is the step with the highest risk of error.
For ordinary gifts or donations, it is not advisable to assume that the taxable value is zero simply because the customer pays zero. The taxable value must be determined according to the VAT regulations applicable to the specific type of transaction.
If the transaction is a promotional activity under commercial law, the business needs to check the tax calculation mechanism for promotional items instead of applying the usual treatment for gifts and donations.
Step 6: Check the tax rate and tax amount.
After determining the taxable value, accountants then determine the tax rate for goods and services at the time of transaction. A fixed tax rate should not be applied internally without first checking the applicable tax policy for the corresponding group of goods and services.
Step 7: Sign, issue, and file the document.
Before issuance, the invoice should be compared with the delivery note, recipient list, gift-giving decision or program, and related documents. The electronic invoice is then signed, transmitted, and stored according to the company's procedures and applicable legal regulations.
What should a sample invoice for free gifts include?
Electronic invoices must comply with mandatory content requirements under current regulations, including information fields about the seller, buyer or recipient (depending on the applicable case), product name, unit of measurement, quantity, unit price, total amount, tax rate, tax amount, and other relevant information.
For example, when a business gives a product to a customer, the business transaction can be expressed as follows:
| Content | Illustrative example |
|---|---|
| Product name | Product A – a gift for customers |
| Quantity | Based on actual delivery quantity |
| Unit price / taxable price | Determine according to the VAT regulations applicable to the transaction. |
| Tax rate | According to the tax rate applicable to the goods at the time of transaction. |
| Pay | No payment obligation arises for the recipient. |
Before signing and issuing an invoice, the accountant should check the following information fields one by one.
Checking in the same order helps to reduce the situation where the goods information is correct but the tax price is incorrect.,
Tax rate or recipient data.
-
ReceiverVerify recipient information against actual data and applicable circumstances.
-
Product nameAccurately reflect the goods being delivered; the explanation "gift" may be added where appropriate.
-
QuantityCompare the actual quantity delivered with the delivery note and related documents.
-
Unit price / taxable priceIt doesn't default to zero just because the recipient has no obligation to pay.
-
Tax rateCheck according to the type of goods and services and the tax policy in effect at the time of occurrence.
-
TaxesVerify the taxable price, tax rate, and tax amount before signing the invoice.
The proposed inspection order is as follows:
Recipient → Goods → Quantity → Taxable Price → Tax Rate → Tax Amount.
The above example illustrates the logic of invoicing and does not replace checking the tax rate, taxable value, and documentation of the specific transaction.
If a customer doesn't request an invoice, is the business still required to issue one?
The fact that the customer or recipient does not request an invoice is not grounds for a business to waive its obligation to issue an invoice if the transaction falls under the cases requiring invoice issuance according to regulations.
Businesses should establish a process for collecting recipient information right from the moment the gift-giving program is approved. For programs with a large number of recipients, data should be standardized before shipment to reduce the need for accounting staff to manually add information after delivery.
In particular, when applying invoicing methods or accompanying lists for programs with multiple recipients, it is necessary to directly refer to the regulations in effect at the time of implementation instead of mechanically using templates from outdated legal guides.
What should be noted when accounting for and declaring goods given away free of charge?
The accounting treatment depends on the purpose of the gift, the source of the goods, the recipient, the accounting system applied by the enterprise, and the actual records.
Therefore, a single accounting entry should not be used for all "free gift" situations. Accountants should separate at least the following cases:
- Businesses that produce or sell goods give them away to customers.
- Purchase goods from the supplier to use as gifts.
- Donating goods to workers.
- These items are part of a promotional program.
- The business receiving the goods is entitled to it as a gift or donation.
For input invoices when a business purchases gifts from a supplier, accountants can refer to the following procedure. Verify the validity of the input invoice. before proceeding with the declaration and archiving steps.
5 common mistakes when issuing invoices for free gifts.
Errors when invoicing for free gifts usually do not stem from data entry mistakes.,
This stems from misidentifying the nature of the business from the outset. The business may have
Mistaking gift items for promotional items, they infer that if no payment is collected, then the price is reasonable.
The tax will be set at zero, or the legal guidance from the previous period will continue to apply.
The table below summarizes the errors that need to be checked before signing and issuing invoices.
| Common errors | Reason | Risk | How to handle it |
|---|---|---|---|
| No invoice was issued because no payment was received. | Confusing the obligation to issue an invoice with whether or not the recipient will pay. | Omission of transactions that require invoicing. | Determine the nature of the transaction before considering payment terms. |
| The taxable value is set to 0 by default. | Equate gift items with promotional items. | Incorrect determination of the taxable value and related tax amount. | Classify the transaction before determining the taxable value. |
| No distinction between gifts and promotions. | Based on the program's internal name rather than its nature and applicable conditions. | Incorrect handling of invoices and taxes may occur. | Check if the program complies with commercial law regulations. |
| Using outdated legal guidance. | Do not check the effective date of the document before applying it. | Applying regulations that are no longer appropriate at the time the transaction occurred. | Compare the text that is in effect on the date of the transaction. |
| The invoice does not match the transaction records. | Do not reconcile data between invoices, inventory, giveaway programs, and recipients. | It is difficult to verify, cross-check, or explain later. | Compare the invoice with the delivery note, decision, list of recipients, and related documents. |
When an invoice has been issued but incorrect information is discovered, businesses need to identify the type of error before choosing how to handle it. See also: Common errors in electronic invoices and how to handle them.
Checklist before issuing a gift invoice.
1. Operations
- Have the items been identified as gifts, promotional items, or samples?
- Has the correct time for goods delivery been determined?
- Do you have the necessary recipient information?
2. Taxes
- Have you checked if the document is in effect at the date it was created?
- Has the basis for calculating the tax been determined?
- Have you checked the applicable tax rates?
3. Documents
- Have you checked the item name, quantity, and delivery note?
- Have you cross-checked the decision, program, or gift list?
- Did you check the invoice before signing and issuing it?
- Are there plans in place for storing, retrieving, and handling errors?
When should businesses automate their invoicing process?
For businesses with only a few gift-giving transactions, accountants can control each document according to existing procedures. The difficulties increase rapidly when the business has many branches, numerous gift-giving programs, a large number of recipients, or when it needs to reconcile data between purchasing, inventory, invoices, and accounting.
In that case, the value of automation lies not in replacing accounting decision-making but in its ability to standardize data, reduce re-entry, and assist in verifying documents before recording.
- Purchasing / Suppliers
Input invoices and purchase data - Warehouse / ERP
Quantity, time of shipment, and actual goods - Gift giving
Program, decision, and list of recipients - Output invoice
Creating, signing, issuing, and managing invoice data. - Accounting / Reconciliation
Verify data and maintain records for declaration and explanation purposes.
Control input invoices when purchasing gifts.
If a business purchases goods from a supplier to use as gifts, the input process requires checking invoices, supplier data, and purchase documents before accounting for the transaction.
Standardizing the creation and management of electronic invoices.
Regarding outgoing invoices, businesses can find out more. B-Invoice electronic invoice To assess the feasibility of standardizing the process of issuing and managing invoice data within the financial system.
Control the budget and costs of gift-giving.
If the pain point lies in approving and controlling the gift budget rather than invoicing, the business can separate the expense management process into a distinct workflow. This is a matter of expense management, not invoicing regulations.
Frequently Asked Questions about Invoices for Free Gift Items
Do free gifts need to be invoiced?
Yes. Current regulations on electronic invoices include goods and services used for giving away or gifting within the scope of business activities that require invoicing. Businesses need to further determine the nature of the transaction to handle the taxable price and related information.
Does a free gift count as a zero-value invoice?
This is not a given. The recipient's failure to pay does not automatically result in the taxable value being zero. A distinction must be made between ordinary gifts and promotional items, and other similar cases.
Is the issuance of gift invoices under Decree 70/2025 still applicable?
For business transactions arising from July 1, 2026, enterprises need to check the new regulations on electronic invoices, including Decree 254/2026/ND-CP, which takes effect from that date.
Do you need to issue an invoice when giving gifts to employees?
Businesses need to determine the nature of the gift, the method of goods transfer, and the related invoicing and tax obligations. They shouldn't simply assume that an invoice isn't required just because the recipient is an employee.
If a customer doesn't want an invoice, is it okay not to issue one?
The fact that the recipient does not request an invoice should not be used as a basis for waiving the obligation to issue an invoice. Accountants need to base their decisions on the regulations applicable to the actual transaction and standardize the collection of recipient data.
Are promotional items the same as gifts?
No. Both transactions may not involve payment, but the legal conditions and methods for determining the taxable value may differ. Therefore, classification is necessary before issuing an invoice.
Conclude
The most important point when issuing invoices for free gifts is: It doesn't start with the amount of money the recipient has to pay, but with the nature of the transaction.. After identifying whether the goods are gifts, promotional items, or samples, the accountant will then determine the invoice date, taxable value, tax rate, and required documentation.
For transactions arising from July 1, 2026, businesses need to check the new regulations on electronic invoices and the VAT regulations in effect at the time of the transaction before applying the process.
To better understand the foundation of this process, please refer to the article. What is an electronic invoice?. Businesses that are processing a large number of invoices may Register for an exchange with Bizzi To evaluate which standardization and automation options are suitable for the current system.
