Bảo Tín Minh Châu case highlights 'two-book' schemes; experts warn that reverting to Excel increases operational burden

On April 6, Hanoi Police charged Vu Minh Chau, founder and owner of the Bao Tin Minh Chau gold brand, along with his son Vu Minh Tu, the head of the independent assistant, and two female accountants for violating accounting regulations causing serious consequences.

Initial investigation results indicate that the company used multiple software systems simultaneously to manage revenue and declare taxes. Internal tools including Hivi Gold, Hivi Gold Pro, and Excel were used to record actual revenue, while Misa was used to prepare reports and file taxes.

Notably, from the second half of 2024, part of the internal data was deleted or altered before being consolidated into the official accounting system.

Revenue gap and alleged impact on the state budget

Extracted results for 2020–2023 show actual revenue of about 13,700 billion VND, which is higher by about 9,700 billion VND than the revenue declared. This discrepancy is reported to have resulted in a state budget shortfall of about 150 billion VND.

Tax authority warning on “two-book” accounting

Regarding “two-book” accounting practices, the Tax Department issued a document requesting relevant units to coordinate to block the practice of operating multiple parallel accounting systems to evade taxes.

The agency said the practice remains that enterprises use software to maintain two accounting systems: one system is used to report to tax authorities, while the internal system records full revenue to reduce tax obligations.

The Tax Department emphasized that establishing multiple accounting books or publishing financial statements that are not aligned in the same period is illegal. If revenue is not fully recorded, it may be treated as tax evasion, potentially leading to criminal prosecution for accounting violations causing serious consequences.

“These are serious violations of tax law as well as the Penal Code,” the agency stressed.

How “two-book” accounting works and related penalties

Le Van Tuan, director of Keytas Accounting Firm, explained that the two books typically used by businesses are the internal book and the tax book. The internal book is kept for internal use within the company, while the tax book is used to report to the tax authority.

In general, the internal book records full revenue and actual costs of business activities, so it usually shows higher revenue and profit than the figures submitted to tax authorities.

When the internal book shows higher revenue than the tax book, a revenue discrepancy arises. According to the expert, this discrepancy is settled using a personal account or cash. As customers have already paid via bank transfer to the business account or the business owner’s account, revenue that has not yet been invoiced or recorded may be received in cash or moved to a personal account.

This means a portion of revenue that has not been invoiced and not recorded is moved to a personal account or received in cash, exposing the firm or business to risks such as penalties for not issuing invoices when selling goods or providing services. Under Decree 310/2025/ND-CP, penalties can reach up to 80 million VND.

Mr. Tuan added that when funds enter a personal account or are received in cash without invoices, the revenue remains unrecorded. The enterprise may be assessed back taxes and fined 1–3 times the evaded tax. More severely, tax evasion can lead to criminal charges.

Expert view: Excel does not solve the core problem

Expert Le Van Tuan said the “two-book” situation largely involves inflating expenses or underreporting revenue. He noted that requiring software providers to share data is only supplementary, and that tax authorities have implemented multiple monitoring measures against these practices.

On the trend of firms reverting to Excel, the expert said this does not resolve the issue and instead increases operational burden and risk. Businesses may spend more time on manual record-keeping, miss opportunities to automate invoicing data, and lose management features of specialized accounting software—while also facing higher error risks.

“Overall, using Excel for accounting does not bring meaningful benefits; on the contrary, it increases operating costs and the pressure of risk control for businesses,” Tuấn emphasized.