Emiting invoices without input invoices: Risks and legal compliance

In daily business operations, many businesses, shops, and sole proprietorships encounter situations where they have issued invoices to customers but have not yet received purchase documents from suppliers. This may be due to supplier delays or internal process weaknesses, but regardless of the cause, the lack of input invoices carries significant risks.

This is not merely an accounting technicality; it directly affects tax obligations, deductible expenses, and even the legal existence of the business. If not handled promptly and correctly, businesses may face administrative penalties, tax back payments, or the risk of being deemed to have used illegal invoices.

This article will help you understand the relevant legal regulations, specific risks associated with missing input documents, how to look up and verify electronic invoices, and intelligent invoice management solutions to prevent violations.

What is an input invoice and why is it important?

According to Decree 123/2020/ND-CP, an invoice is an official accounting document issued by the seller upon delivery of goods or provision of services. Input invoices are the documents a business receives from suppliers when purchasing raw materials, goods, services, or assets for production and business purposes.

The role of input invoices extends beyond simply proving sales transactions. They also serve as the basis for deducting value-added tax, calculating deductible expenses when settling corporate income tax, and proving the origin of goods during inspections by authorities. The absence of input invoices means that a business cannot prove incurred expenses, even if they have been fully paid.

Does the law allow issuing output invoices without input invoices?

According to Article 9 of Decree 123/2020, as amended by Decree 70/2025, the time of issuing an output invoice is specified as follows:

For goods sales, the invoice must be issued at the time of transferring ownership or the right to use the goods to the buyer, regardless of whether payment has been received. For services, the invoice must be issued immediately upon completion of the service, or upon receipt of payment if payment is received before or during the service provision.

This regulation does not require businesses to have input invoices before issuing output invoices. However, this does not mean businesses can conduct business freely without input documents. The law requires all purchase and sale transactions of goods and services from registered organizations and individuals to have invoices. Failure to present input invoices when necessary will result in a series of severe legal and financial consequences for the business.

Specific risks of missing input invoices

Loss of VAT deduction rights

When there are no valid input invoices, businesses cannot deduct the VAT paid to suppliers. This significantly increases the amount of tax payable. For example, if you sell goods and issue an invoice worth 220 million VND, including 20 million VND in VAT, but have no input invoices for deduction, you will have to pay the entire 20 million VND instead of just the difference between output and input tax.

Expenses not recognized during tax settlement

For an expense to be considered a deductible expense, it must be supported by complete invoices and documents. If input invoices are missing, all expenses for purchasing goods and services will be excluded from deductible expenses when calculating corporate income tax. Consequently, taxable profits increase, and businesses have to pay more corporate income tax than they should.

Risk of administrative penalties

According to Decree 98/2020 and its amendments, if a business trades goods of unknown origin or source, penalties can reach tens of millions of VND depending on the value of the goods. Specifically, if the value of goods is from 100 million VND or more, the penalty can range from 40 million to 50 million VND.

Tax back payment and late payment interest

During inspections and audits, tax authorities will compare input and output invoices. If discrepancies are found regarding input documents, businesses may be required to pay back both VAT and corporate income tax, along with daily late payment interest. This represents a significant financial loss, especially for small businesses.

Impact on reputation and business operations

Lack of transparency in accounting documents can lead partners, banks, and authorities to doubt the legality of business operations. This affects the ability to secure loans, participate in bidding, and cooperate with major partners.

Risk of criminal prosecution

In cases of suspected fraud or the use of illegal invoices, businesses may face criminal prosecution. This is the most serious risk, potentially leading to imprisonment or suspension of business operations.

How to look up and verify input electronic invoices

To proactively manage and verify the validity of input invoices, businesses can directly search on the General Department of Taxation's portal. Here are the detailed steps:

Step 1: Access the website https://hoadondientu.gdt.gov.vn

Step 2: Log in using the tax code and password provided by the tax authority.

Step 3: On the main interface, select "Tra cứu" (Lookup), then select "Tra cứu hóa đơn" (Invoice Lookup).

Step 4: Continue to select "Tra cứu hóa đơn điện tử mua vào" (Lookup Input Electronic Invoices).

Step 5: Enter the supplier's tax code if you want to search for invoices from a specific supplier. If you want to view all input invoices, you can leave this field blank.

Step 6: Select "Tất cả" (All) in the "Kết quả kiểm tra" (Verification Result) section, or filter by specific status if needed.

Step 7: Enter the desired lookup period in the "Ngày lập hóa đơn" (Invoice Date) field.

Step 8: Click "Tìm kiếm" (Search). The system will display results under two tabs: "Hóa đơn điện tử" (Electronic Invoices - containing invoices with tax authority codes) and "Hóa đơn khởi tạo từ máy tính tiền" (Invoices generated from cash registers - if applicable).

If you need to export the invoice list, you can click the "Xuất hóa đơn" (Export Invoice) button to download an Excel file for reconciliation and storage.

Intelligent Invoice Management Solution with GTG CRM

To avoid the risks of missing input invoices and ensure legal compliance, businesses need a robust and automated document management system. GTG CRM provides comprehensive invoice management features, helping businesses tightly control both output and input invoices.

Automatic and accurate output invoice issuance

GTG CRM allows businesses to issue output electronic invoices immediately upon sales transactions. The system automatically synchronizes information from orders, saving time and minimizing errors. All invoices are stored securely and are easily searchable and reconcilable when needed.

Automatic collection and management of input invoices

One of GTG CRM's standout features is its ability to automatically collect input invoices. The system connects directly to email, automatically downloads and stores all incoming purchase invoices (invoices sent to the email). This eliminates the worry of lost documents or forgotten invoice reconciliations for accountants.

Tangible benefits of using GTG CRM

Firstly, businesses will always have complete input documents to prove the origin of goods, avoiding penalties or tax back payments. Secondly, reconciling input and output invoices becomes simple and quick, allowing for timely detection of discrepancies or omissions. Thirdly, businesses can fully deduct VAT, optimizing tax obligations and reducing unnecessary costs.

Secondly, all documents are stored electronically, making them easy to retrieve for reporting, audits, or tax settlements. Finally, the system helps businesses fully comply with legal invoice regulations, avoid legal risks, and protect their business reputation.

Conclusion

Issuing output invoices without input invoices is not just a technical issue but also carries significant legal and financial risks. Businesses must proactively manage their documents rigorously, utilize supporting tools to automate processes, and ensure full compliance with regulations. GTG CRM, with its automatic output invoice issuance and input invoice collection features, is a comprehensive solution that helps businesses operate transparently, efficiently, and more securely in the digital age.