There is no basis to fine business households with revenue below 500 million VND for using electronic invoices

Lục Giang |

The request to stop using electronic invoices for business households with revenue below 500 million VND is causing controversy, experts believe that there is no basis for sanctioning.

Business households under 500 million VND/year stop using electronic invoices

According to a notice from the Base Tax Department of 7 provinces of Dak Lak, some business households are subject to stopping the use of electronic invoices.

Cases include: Business households that have registered to use electronic invoices from 2025 or earlier, with revenue in 2025 less than or equal to 500 million VND and accumulated revenue from the beginning of 2026 to the time of determination also not exceeding 500 million VND; Business households that have just registered in 2026, have registered to use electronic invoices but accumulated revenue from the beginning of the year to the time of determination does not exceed 500 million VND.

The tax authority requires households in this category to stop using electronic invoices from the time of receiving the notice, and at the same time not to continue issuing invoices during the time not subject to application.

In case of continuing to issue electronic invoices, this act may be identified as using illegal invoices and will be penalized according to regulations.

After stopping using invoices, business households must record revenue generated in the revenue book as a basis for tax declaration.

The tax authority said that business households will be allowed to reuse electronic invoices when accumulated revenue from the beginning of 2026 to the time of determination exceeds 500 million VND. At that time, if there is a need, business households will register to use electronic invoices according to current regulations.

In case business households have revenue in the first quarter of 2026 exceeding 500 million VND, they can still continue to use electronic invoices and must submit the tax return for the first quarter no later than May 4.

No basis for punishment

According to Ms. Nguyen Thi Cuc - Chairwoman of the Vietnam Tax Consultants Association, the tax authority has thoroughly grasped the principle of not penalizing in case of problems arising when implementing policies. Therefore, business households that comply with regulations and proactively issue invoices in cases that are not compulsory do not have a basis for being penalized.

However, in reality, the understanding and application in localities are still not consistent. Some places consider issuing invoices when not compulsory as a violation and may be penalized, while others provide more flexible guidance, allowing taxpayers to contact for support in handling.

Ms. Cuc said that the Vietnam Tax Consultants Association has proposed that the Ministry of Finance and tax authorities soon issue clear and unified guidelines throughout the system. According to the proposal, business households and individuals with revenue of 500 million VND/year or less - not subject to value-added tax and personal income tax - can still request tax authorities to issue invoices when customers have demand.

Choice should be allowed instead of banning the use of electronic invoices

Mr. Le Van Tuan - Director of Keytas Tax Accounting Co., Ltd. said that not allowing households and individuals doing business with revenue below 500 million VND to use electronic invoices raises many issues about rationality in practice.

According to Mr. Tuan, currently regulations encourage business households and individuals with revenue of less than 1 billion VND to use electronic invoices. Meanwhile, for groups with revenue of less than 500 million VND, the buyer of goods and services can still make a list to calculate deductible expenses when determining taxes.

That is, instead of electronic invoices, the parties must use lists to replace them. So why not allow the continued use of electronic invoices, which are more convenient and transparent?", Mr. Tuan raised the issue.

From a management perspective, he believes that electronic invoices help tax authorities track revenue, expenses and especially the tax threshold of 500 million VND more easily and accurately. Conversely, the use of business statements or revenue books self-declared by business households will be more difficult to control.

For buyers, the statement not only takes time to prepare but also poses risks when determining valid costs. Therefore, many businesses tend to choose suppliers that can issue electronic invoices to ensure legal safety.

In case the business household's revenue exceeds 500 million VND and is subject to tax, then subsequent transactions must have electronic invoices. At that time, whether the pre-made statements are still accepted as valid costs is also an issue that makes buyers hesitant," Mr. Tuan analyzed.

On the seller's side, not being able to use electronic invoices can also reduce the ability to reach customers, especially business customers. In addition, having to provide personal information such as citizen identification cards to make statements also makes many business households worried in the context of increasing fraud risks.

Overall, Mr. Tuan believes that the use of inventories may increase social costs, from time, procedures to storage costs, while transparency and reliability are not as high as electronic invoices.

From there, this expert suggested that instead of banning or requiring, management agencies should allow households and individual businesses to choose to use electronic invoices, even when revenue is below the threshold of 500 million VND.

The right to choose is always the appropriate solution in creating a favorable and flexible business environment for people," Mr. Tuan stated his point of view.

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