VCCI has responded to Official Dispatch No. 1535/BTC-CT dated February 5, 2026 of the Ministry of Finance on requesting comments on the Draft Decree amending and supplementing Article 9 of Decree 123/2020/ND-CP on invoices and documents, amended and supplemented by Decree 70/2025/ND-CP.
Proposal for electronic invoices for household businesses not to require recording tax codes for buyers
According to VCCI, Article 11 (amended) of Decree 123/2020/ND-CP stipulates that business households and individual businesses with revenue from 1 billion VND/year are responsible for using electronic invoices (E-invoices) with electronic data transfer connections with tax authorities. Accordingly, invoices must have a tax code or personal identification number of the buyer.
This regulation causes significant difficulties for business households, especially in the retail sector (epiceries, mini-supermarkets), food or accommodation (hotels). The reason is that the specific characteristics of these sectors are large retail customers, small transaction value and fast trading time. The requirement to record complete buyer information on each invoice not only incurs additional costs for hiring additional labor in charge of cashier, invoice costs (high compared to transaction value), but also causes discomfort for consumers.
Meanwhile, supermarkets, shopping centers, and gas stations, which have characteristics similar to business households in the retail sector, are exempt from applying this regulation. In the context that tax policies for business households and individuals are changing comprehensively, amending this regulation is very necessary to synchronize between tax policies and invoices, without creating a large burden of compliance for business households and individuals in the transition process.
Therefore, it is proposed that the drafting agency allow e-invoices of business households not necessarily to have a tax identification number or personal identification number of the buyer in case the buyer is a non-business individual.
Electronic invoice for passenger transport services with organizational customers
In addition, VCCI said that, according to feedback from businesses, currently, ride-hailing platforms have a segment of customers who are organizations and businesses that sign contracts to use services in the form of using services first, paying later according to a fixed cycle.
Customers only need to get value-added invoices based on the summary table for the purpose of transaction reconciliation at the end of the cycle. This model is completely consistent with the criteria allowing invoicing according to the conventional period as stipulated in point b, clause 6, Article 1 of Decree 70/2025/ND-CP (amended point a, clause 4, Article 9 of Decree 123/2025/ND-CP), including: Selling goods and services in large quantities, arising frequently, requiring time to reconcile data between businesses selling goods, providing services and customers.
However, currently, Decree 123/2020/ND-CP (amended by Decree 70/2025/ND-CP) and the Draft have not yet listed in the list of industries and fields applying this regulation. This causes many difficulties for both the ride-hailing platform and businesses using the service. Accordingly, the platform must issue thousands to millions of individual invoices, instead of a total invoice in one period, increasing operating costs and data related to invoices, and at the same time causing overload for the system of customer businesses.
In addition, this huge number of invoices is also directly connected to the tax authority's system, putting more pressure on infrastructure and management for the tax authority. Moreover, the issuance of total invoices does not affect tax obligations and there is no risk of tax loss because the platforms have fully and transparently declared, deducted, and paid taxes instead according to legal regulations.
Therefore, VCCI proposes that the drafting agency supplement passenger transport service activities (by taxi, contract car, two-wheeled motorbike) using billing software, transport connection support software according to the provisions of the Road Law, provided to customers who are businesses and organizations in Article 9. 4. a Decree 123/2020/ND-CP (amended by Decree 70/2025/ND-CP).
