How Are Import Duty and Import VAT Included in the Cost of Imported Goods?
Businesses often add every amount paid at customs into “cost of goods,” creating two common distortions: capitalising deductible import VAT, or omitting import duty and directly attributable logistics costs. The result is an unreliable margin, unsupported selling prices and insufficient import cash planning. This article separates three data layers: tax payable on the customs declaration, inventory cost recognised in accounting, and actual cash required at import.
QUICK FACTS
The portion of import duty that is not exempted, refunded or subject to non-collection normally forms part of inventory or relevant asset cost.
For VAT-taxable imports, VAT payable belongs in the cash plan; only the non-deductible portion increases inventory or the related cost.
In a common case, the VAT base includes customs value, import duty, supplementary import duties and other applicable taxes.
The customs exchange rate used for tax is not automatically the accounting rate used for payables and inventory.
SCOPE OF APPLICATION
This article mainly applies to Vietnamese businesses importing goods for trading, production or use as assets. The worked formula focuses on VAT-taxable imports and ad valorem import duty. Non-VAT imports, absolute or mixed duties, excise tax, environmental protection tax, supplementary/trade-remedy duties, exemptions and special customs regimes require a separate calculation model.
KEY TERMS
| Term | Meaning | Cost relevance |
|---|---|---|
| Customs Value | The value used as the tax base, generally starting from transaction value and adjusted under customs valuation rules. | Tax base, but not necessarily identical to accounting purchase cost. |
| Import Duty | Duty under MFN, FTA special preference, ordinary rates, or absolute/mixed methods. | Non-refundable duty normally forms part of inventory cost. |
| Import VAT | VAT arising at importation for goods within the scope of VAT. | Where it arises, this is a cash outflow; it is recorded as deductible input VAT when conditions are met, otherwise included in inventory/asset cost or the relevant expense. |
| Landed Cost | Total cost to bring goods to the location and condition ready for sale or use. | Used for pricing and margin analysis; not identical to customs tax payable. |
| COGS | Inventory cost recognised as expense when goods are sold. | Import-related taxes and costs generally enter inventory first, then flow to COGS as units are sold. |
OPERATING MECHANISM
Use three separate management ledgers:
Customs value, tax rates and amounts payable for clearance.
Inventory/asset cost, deductible input VAT and foreign-exchange differences.
Allocation by SKU, order and sales channel for landed-cost pricing.
Customs value is not automatically the book value. Customs applies valuation rules and the customs tax exchange rate on the declaration date, while accounting follows the entity’s accounting exchange-rate policy. A difference can be valid when supported by a reconciliation.
TAX AND COST FORMULAS
The applicable import-duty rate may be MFN, FTA special preferential or another rate depending on origin and documents. The VAT rate must also be checked against the product and policies effective on the declaration date.
COST-COMPONENT ANALYSIS
Assume an import customs value of VND 1,000,000,000, import duty of 5%, VAT of 10%, no excise or environmental protection tax, and VND 80,000,000 of directly attributable freight, local charges, customs processing and delivery. Figures are illustrative only.
| Item | Calculation | Amount | Management treatment |
|---|---|---|---|
| Import duty | 1,000,000,000 × 5% | 50,000,000 | Normally included in inventory cost. |
| VAT taxable base | 1,000,000,000 + 50,000,000 | 1,050,000,000 | VAT base in this example. |
| Import VAT | 1,050,000,000 × 10% | 105,000,000 | Cash required at import. |
| Inventory cost if VAT is deductible | 1,000,000,000 + 50,000,000 + 80,000,000 | 1,130,000,000 | VND 105 million is tracked as input VAT, not inventory cost. |
| Inventory cost if VAT is non-deductible | 1,130,000,000 + 105,000,000 | 1,235,000,000 | Non-deductible VAT increases cost. |
| Tax cash-out at import | 50,000,000 + 105,000,000 | 155,000,000 | Not the same as accounting expense for the period. |
WHICH TAXES ENTER COST?
| Tax | Included in cost? | Key condition | Cash impact |
|---|---|---|---|
| Import duty | The non-recoverable portion normally yes | Check exemption, refund, non-collection and special customs-regime treatment. | Payment, guarantee or deferral timing depends on the regime and taxpayer eligibility. |
| Fully deductible import VAT | Normally no | The goods must be VAT-taxable; check VAT method, tax-payment evidence, business use and deduction conditions. | Where VAT arises, it is still paid at import before later deduction. |
| Non-deductible import VAT | Yes, or recorded in the related asset/expense | Non-taxable activities, missing conditions or statutory deduction limits. | Permanent economic cost. |
| Partially deductible import VAT | Only the non-deductible portion | Allocation ratio and supporting records. | Full VAT may be paid first; deductible portion is tracked separately. |
| Excise, environmental, supplementary import and other taxes | Only the portion not refundable, creditable or offsettable | Review the recovery, credit or offset mechanism under each tax; do not assume every amount paid enters cost. | Amounts listed in Article 7 of the VAT Law may also increase the import VAT taxable base. |
DOCUMENTS AND DATA TO CHECK
| Document/data | Prepared/issued by | Use | Fields to reconcile |
|---|---|---|---|
| Contract, invoice, packing list | Buyer and seller | Purchase price, Incoterms and product description | Currency, quantity, unit price and buyer-paid items. |
| Technical file and proposed HS code | Importer/manufacturer | Duty and product policy | Composition, function, material, model and specifications. |
| C/O and origin evidence | Competent issuer/exporter under the FTA mechanism | Special preferential duty claim | Form, origin criterion, transport, third-party invoicing and validity. |
| Customs declaration and tax-payment evidence | Importer, Customs and bank | Tax liability and input VAT | HS, value, rate, amount, date and reference. |
| Freight invoices and debit notes | Forwarder, carrier, terminal, warehouse and trucker | Direct import cost | Scope, shipment reference and domestic service VAT. |
| Landed-cost allocation sheet | Finance/accounting/supply chain | SKU allocation and COGS | Consistent allocation driver and no duplicate VAT. |
PROCESS FOR CALCULATION AND ALLOCATION
- Lock product descriptions and proposed HS codes. Separate lines with different tax rates.
- Build tax scenarios. MFN, valid FTA preference, no C/O, and absolute/mixed duty where relevant.
- Prepare a valuation bridge. Separate accounting purchase price, customs value and Incoterms adjustments.
- Calculate by customs line. Import duty first, then the VAT base and VAT.
- Determine VAT status. No VAT because the import is outside the VAT scope, or VAT arises and is fully, partially or non-deductible.
- Accumulate direct costs. Freight, insurance, local charges, clearance, inspection and delivery. Separate abnormal storage, penalties, DEM/DET and delay-driven costs for accounting-policy assessment instead of automatically capitalising them.
- Allocate to SKUs. Duty by HS line; common costs by weight, CBM, value, packages or a causal hybrid.
- Reconcile three totals. Customs tax, logistics/payables and inventory receipt.
RISKS AND COMMON ERRORS
| Error | Cause | Impact | Control |
|---|---|---|---|
| Capitalising all import VAT | Confusing tax cash-out with economic cost | Overstated inventory and margin distortion | Separate deductible and non-deductible VAT columns. |
| Excluding VAT from cash planning | Assuming deduction eliminates payment | Clearance funding shortfall | Maintain a separate import cash-out report. |
| Using customs value as absolute book cost | No exchange-rate or adjustment bridge | Mismatch in payables, inventory and FX | Reconcile invoice, customs value and book value. |
| Averaging duty across all SKUs | Ignoring HS-line tax rates | Wrong SKU margin | Assign duty directly by customs line first. |
| Budgeting on an unverified C/O | No origin-rule review | Underfunding if preference is rejected | Prepare with-C/O and without-C/O scenarios. |
| Double-counting international freight | CIF/CIP invoice plus full freight added again | Overstated landed cost | Review Incoterms and valuation components. |
| Capitalising every local charge, DEM/DET and abnormal cost | Normal directly attributable costs are not separated from delay, penalty or inefficiency costs | Overstated inventory and weak audit support | Capitalise only costs directly bringing goods to the required location and condition; assess abnormal costs separately under the accounting policy. |
LEGAL BASIS AND SOURCES
The following sources were checked through 17 July 2026. Apply the version effective on the customs declaration date and review relevant FTA tariff decrees, temporary VAT policies and product-specific rules.
| Instrument / source | Issuer – effectiveness | Role in this article |
|---|---|---|
| Law 107/2016/QH13 on Export and Import Duties, as relevantly amended by Law 90/2025/QH15 | National Assembly; review the current consolidated legal chain | Tax bases, calculation methods and import-duty principles. |
| Decree 26/2023/ND-CP as amended by 144/2024, 108/2025 and 199/2025 | Government; apply the version effective on the declaration date | MFN import tariff and related duty schedules. |
| VAT Law 48/2024/QH15, amended by Law 90/2025/QH15, Law 149/2025/QH15 and Law 09/2026/QH16 | National Assembly; legal chain current through 17 July 2026 | Import VAT taxable value, rates and deduction principles. |
| Decree 181/2025/ND-CP, amended by 359/2025/ND-CP and 144/2026/ND-CP | Government; Decree 144/2026 effective 20 June 2026 | Detailed implementation of the VAT Law. |
| Circular 69/2025/TT-BTC | Ministry of Finance; effective 1 July 2025 | Operational VAT guidance and supporting-document rules. |
| Ministry of Finance confirmation of the application date of Circular 99/2025/TT-BTC | Ministry of Finance; applies to financial years beginning on or after 1 January 2026 | Current enterprise accounting framework for inventory, taxes and COGS recognition. |
| Customs information on Circular 60/2019/TT-BTC | Vietnam Customs; amends customs-valuation rules | Customs value is determined from the transaction and required adjustments, not merely the invoice total. |
FAQ
1. Does deductible import VAT mean there is no cash cost?
For VAT-taxable imports, no. The tax is still paid at import; deduction affects subsequent VAT accounting, not the initial cash requirement.
2. Is import duty expensed immediately?
For trading inventory, it normally enters inventory cost and flows to COGS when the related goods are sold.
3. Does VAT on domestic logistics enter inventory cost?
Deductible service VAT is separated; the net service amount is the direct cost. Non-deductible VAT may increase inventory or the relevant expense.
4. Does a C/O guarantee 0% import duty?
No. The agreement, origin criterion, HS code, transport and document validity must all be satisfied; some preferential rates remain above 0%.
5. Must FOB price be increased by freight and insurance for customs value?
Costs to the first import border may need to be considered under valuation rules. The actual adjustment depends on the documents and transaction terms.
6. Should all costs be allocated by goods value?
No. Duty follows HS lines; ocean freight may follow CBM/weight; documentation may be per shipment; trucking may be per trip.
7. When should landed cost be recalculated?
After tax assessment/refund, supplemental debit notes, value adjustments, quantity differences, new charges or a change in VAT deductibility.
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