Guidelines on Transition to E-Invoices Effective from June 1, 2025

On May 31, 2025, the Minister of Finance issued Circular No. 32/2025/TT-BTC guiding the implementation of several provisions of the Law on Tax Administration 2019, Decree No. 123/2020/ND-CP on invoices and documents, and Decree No. 70/2025/ND-CP amending and supplementing several provisions of Decree No. 123/2020/ND-CP.

This Circular takes effect from June 1, 2025, and clearly stipulates the transition to e-invoices to enhance management efficiency, increase transparency in tax declaration, and support taxpayers in using e-invoices.

1. Transition to E-Invoices

1.1. Taxpayers currently using e-invoices without a tax code

• If wishing to switch to using e-invoices with a tax code issued by the tax authority, taxpayers must update their e-invoice usage information in accordance with Article 15 of Decree No. 123/2020/ND-CP (as amended by Clause 11, Article 1 of Decree No. 70/2025/ND-CP dated March 20, 2025).

1.2. Taxpayers eligible to use e-invoices without a tax code under the 2019 Tax Administration Law

• According to Clause 2, Article 91 of the Law on Tax Administration 2019, if deemed high-risk according to Circular No. 31/2021/TT-BTC dated May 17, 2021 and notified by the tax authority via Form No. 01/TB-KTT (Appendix IB issued with Decree No. 70/2025/ND-CP), they must switch to using e-invoices with a tax code issued by the tax authority.

• Taxpayers must update their e-invoice usage information within 10 working days from the date of receiving the notification.

• The transition must comply with Article 15 of Decree No. 123/2020/ND-CP (as amended by Clause 11, Article 1 of Decree No. 70/2025/ND-CP).

1.3. After 12 months of using e-invoices with a tax code

• If taxpayers wish to revert to using e-invoices without a tax code, they must file for information change as regulated in Article 15 of Decree No. 123/2020/ND-CP (amended by Clause 11, Article 1 of Decree No. 70/2025/ND-CP).

• The tax authority will review and decide based on Clause 2, Article 91 of the Law on Tax Administration 2019 and Circular No. 31/2021/TT-BTC.

2. Applying E-Invoices for Enterprises with Multiple Business Activities

• Enterprises may register to use:

  • E-invoices generated from cash registers for retail and service activities directly to end consumers such as: shopping malls, supermarkets, retail (excluding automobiles, motorbikes, and other motor vehicles), food & beverage, restaurants, hotels, passenger transport, road transport support services, entertainment, cinema, and other personal services as defined by Vietnam’s Economic Sector Classification.

  • E-invoices with or without tax codes for other business activities.

3. Important Notes

• The transition to e-invoices must strictly comply with legal provisions. The process of updating invoice usage information must strictly follow Article 15 of Decree No. 123/2020/ND-CP and the amendments in Decree No. 70/2025/ND-CP.

• Taxpayers must proactively monitor and coordinate with tax authorities to receive notifications and carry out timely transitions.

• Switching to e-invoices with tax codes enhances transparency in tax management, reduces risks of tax fraud, and facilitates invoice management and storage.

4. Legal Basis

• Circular No. 32/2025/TT-BTC of the Ministry of Finance, effective from June 1, 2025.

• Decree No. 123/2020/ND-CP on invoices and documents.

• Decree No. 70/2025/ND-CP amending Decree No. 123/2020/ND-CP.

• Law on Tax Administration 2019.

• Circular No. 31/2021/TT-BTC on risk assessment in tax management.

For inquiries or support regarding the transition to e-invoices, please contact the Hotline: 084 877 0777 for immediate consultation.

Viet Australia
Viet Australia Auditing Company is an independent auditing organization licensed and established in 2007 in the Socialist Republic of Vietnam.