Vietnam Tax Department Guidance on Risk-Based VAT Refund Assessment

Vietnam’s Tax Department issued guidance on using risk-based assessment for VAT refund claims, especially where the taxpayer or supply-chain counterparties are flagged by the tax risk system.
A risk alert about a supplier or upstream party is only a risk indicator and does not, by itself, prove a transaction is fake, an invoice is invalid, or input VAT is non-refundable. Refund denial or recovery must be based on inspection/verification findings or a competent authority’s conclusion.
In refund-first, audit-later cases, only the high-risk portion of a refund claim may be subjected to pre-refund inspection; the non-risk portion should still be processed normally if it meets refund conditions.
Upstream supply-chain risks (F2, F3, etc.) can feed into the assessment of the direct supplier (F1), but such upstream alerts alone cannot automatically make the taxpayer’s input VAT subject to pre-refund inspection or ineligible for refund.
Supplier status issues such as ceasing operations, not operating at the registered address, dissolution, or tax-registration termination are also only risk information and do not automatically disqualify the taxpayer’s VAT refund claim.

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.