How Should Items [37] and [38] on VAT Return Form No. 01/GTGT Be Completed Under Circular No. 89/2026/TT-BTC?
VAT Return Form No. 01/GTGT (applicable to taxpayers using the VAT credit method for business activities) is prescribed in Appendix I of Circular No. 89/2026/TT-BTC.
Under the new regulations, the guidance for completing Items [37] and [38] has been significantly revised, introducing several new reporting scenarios.
1. Goods and Services Purchased on Deferred or Installment Payment Terms
Where goods or services valued at VND 5 million or more are purchased on deferred or installment payment terms without non-cash payment evidence, the taxpayer must:
- Declare the reduction of deductible input VAT in Item [37] during the tax period in which the payment obligation arises under the contract or contract appendix.
Once valid non-cash payment evidence is obtained, the taxpayer may:
- Declare the deductible input VAT in Item [38] during the tax period in which the payment evidence is available.
2. Errors in Declared or Credited Input VAT
If the taxpayer discovers errors in previously declared input VAT and correcting those errors only:
- Reduces the VAT payable; or
- Increases or decreases the deductible VAT carried forward,
the adjustment should be reported directly in Item [37] or Item [38] in the tax period when the error is discovered.
No amended VAT return for the original tax period is required.
3. Receipt of Adjustment or Replacement E-Invoices
Where the purchaser receives an adjustment invoice or replacement invoice in cases such as:
- Returned goods;
- Trade discounts; or
- Post-settlement adjustments,
the taxpayer must declare the adjustment in Item [37] or Item [38] for the current tax period in which the adjusted or replacement invoice is received.
An amended VAT return is not required.
4. Conversion from the VAT Credit Method to the Direct Method
When changing from the VAT credit method to the direct VAT method, the taxpayer must:
- Declare the reduction of the entire remaining deductible input VAT balance in Item [37] of the last tax period before the conversion.
No amended VAT return is required.
5. Other Cases
Other adjustments relating to Items [37] and [38] shall be made in accordance with:
- Article 12 of Decree No. 252/2026/ND-CP; and
- Appendix II of Circular No. 89/2026/TT-BTC.
Other Notable Changes to VAT Return Form No. 01/GTGT
Item [01a] – Business Activity Selection
Taxpayers must select the applicable business activity, including:
- Ordinary business activities;
- Lottery business;
- Oil and gas exploration and production;
- Infrastructure investment projects or housing projects located outside the province where the head office is situated;
- Power plants located outside the province where the head office is situated.
Items [09], [10], and [11] – Dependent Units
These items are used to declare information on dependent units or business locations situated in provinces different from the taxpayer’s head office.
Where multiple dependent units exist, one representative unit must be selected for reporting in accordance with the tax authority’s management structure.
Item [32b]
Declare the value of goods and services that are excluded from the VAT taxable value under the VAT regulations.
Item [39a]
Declare deductible VAT balances transferred from:
- Investment projects that have commenced operations;
- Dependent units that cease operations; or
- Enterprises undergoing division, separation, merger, consolidation, or restructuring.
Item [40b]
Declare the total VAT amount previously reported in Items [28a] and [28b] of VAT Return Form No. 02/GTGT.
Comparison with Previous Regulations
Under the previous guidance in Circular No. 80/2021/TT-BTC, as amended by Circular No. 40/2025/TT-BTC, Items [37] and [38] were generally used only to declare VAT adjustments arising from amended tax returns.
Under Circular No. 89/2026/TT-BTC, the scope of these items has been significantly expanded. Taxpayers may now report various VAT adjustments directly in the current tax period—such as installment purchases without non-cash payment evidence, correction of input VAT errors, receipt of adjustment or replacement invoices, and conversion of VAT calculation methods—without filing an amended VAT return for the original period.
Key Takeaway
Effective 1 July 2026, Circular No. 89/2026/TT-BTC introduces a more streamlined approach to completing Items [37] and [38] on VAT Return Form No. 01/GTGT, allowing many VAT adjustments to be reported in the current tax period rather than requiring amended tax returns, thereby simplifying tax compliance for businesses.
