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A draft decree on electronic invoices has prompted surprise among many household businesses (HKD) after local tax authorities issued notices requiring HKD with annual revenue under 500 million VND to stop using electronic invoices and to cancel already registered invoices. The Ministry of Finance is still reviewing the draft decree, which would define that HKD and individuals not subject to VAT and not liable to personal income tax would not use electronic invoices.
Under the draft decree, HKD with annual revenue up to 500 million VND would not be required to issue electronic invoices. However, while the decree remains in draft form, some local tax authorities have already circulated notices instructing HKD under the threshold to cease using electronic invoices and cancel invoices that have been registered.
Local authorities warn that continuing to use electronic invoices could lead to penalties, even though formal, uniform guidance from the Ministry of Finance has not yet been issued.
The requirement has drawn mixed reactions from HKD owners and industry representatives.
Ms. N.H.H., owner of a stationery HKD in Tay Tựu Ward (Hanoi), said many of her customers are other small businesses that often need invoices for cost accounting. She worries that if electronic invoicing is not available soon, she may lose customers, noting that in practice invoice use has become nearly mandatory in many transactions.
Other voices argue the rule could create barriers and slow the expansion of HKD. They also note that the broader policy objective is to promote transparency and modern management.
The Haravan executive, Mr. Nguyen Gia Bao Long, said electronic invoices are one basis for determining tax obligations. He questioned whether a blunt 500 million VND threshold as a hard stop is appropriate, arguing that some businesses below the threshold are well managed and still need to issue invoices, while some above the threshold operate in ways that may not require invoicing. He warned that rigid application could encourage revenue splitting or lead some businesses to forgo invoicing, potentially harming transparency.
Tax expert Dr. Nguyen Hong Trang emphasized that using the threshold as a firm switch is not ideal. While a revenue threshold is necessary, treating it as a binary trigger may not fit real-world practice. She said a rigid approach could discourage transparency rather than promote it.
Mr. Nguyen Ngoc Tinh, Vice Chairman of the Ho Chi Minh City Tax Advisory and Tax Agency Association, added that mandating all HKD to use invoices is not feasible due to resource constraints and compliance costs for small businesses. He noted that invoices remain essential for determining VAT and personal income tax obligations, and said long-term solutions should enable HKD to use invoices without adding costs, while preserving transparency in financial transactions.
On April 15, Ho Chi Minh City tax leaders stated that some local tax authorities may already apply the 500 million VND revenue threshold under the Tax Administration Law while awaiting formal guidance from the Ministry of Finance, which has not yet issued uniform instructions.
Transitional provisions are expected to allow HKD with revenue under 500 million VND to continue using electronic invoices through the end of 2026 before nationwide implementation. After official guidance is released, Ho Chi Minh City Tax said it will announce the threshold, the cessation date, and transition rules.
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