According to opinions of the General Department of Vietnam Customs, Article 24 of Customs Law and point b clause 1 Article 16 of Circular No. 38/2015/TT-BTC (amended at clause 5 Article 1 of Circular No. 39/2018/TT-BTC), enterprises are only required to submit commercial invoices upon making procedures for exporting goods without mandatory issuance of electronic VAT invoices to submit in the customs dossier for exports.
In addition, at point b, point c clause 3 Article 13 of Decree No. 123/2020/ND-CP also regulate that time of issuance of VAT invoices for exports is after completion of customs procedures (it is not required to issue VAT invoices before making customs procedures for exports as commercial invoices).