Is it necessary to re-register the use of e-invoices after the administrative division change at the commune level in Ho Chi Minh City?
Is it necessary to re-register the use of e-invoices after the administrative division change at the commune level in Ho Chi Minh City?
Based on Official Dispatch 108/CTTPHCM-TTHT 2025 from the Ho Chi Minh City Tax Department guiding the administrative boundary changes according to Resolution No. 1278/NQ-UBTVQH15 as follows:
In cases where the taxpayer's registered address is affected by the administrative boundary changes pursuant to Resolution No. 1278/NQ-UBTVQH15 dated November 14, 2024, of the National Assembly Standing Committee, regarding the rearrangement of administrative units at the commune level for the period 2023-2025 in Ho Chi Minh City, whereby the address information on the taxpayer’s Business Registration Certificate is no longer appropriate, the Tax Department requests that the taxpayer urgently contact the business registration authority to update the new address. Additionally, for e-invoices, it is recommended that the enterprise register again the information for using invoices according to Form No. 01/ĐKTĐ-HĐĐT issued with Decree 123/2020/ND-CP of the Government of Vietnam and ensure that the enterprise's address content on the e-invoice matches the address on the Business Registration Certificate as per regulation.
In addition, Clause 4, Article 15 of Decree 123/2020/ND-CP also stipulates as follows:
Registration, change of information registered for using e-invoices
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- In cases of changes in the information registered for e-invoice use mentioned in Clause 1 of this Article, businesses, economic organizations, other organizations, households, and individual businesses shall make the necessary information changes and resubmit to the tax authority using Form No. 01/ĐKTĐ-HĐĐT Appendix IA, issued with this Decree, through the General Department of Taxation's e-portal or through an e-invoice service provider, except in cases of termination of e-invoice usage as stipulated in Clause 1, Article 16 of this Decree. The General Department of Taxation’s e-portal will accept the re-registration form and the Tax Authority will process it according to the provisions at Clause 2 of this Article.
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For cases where the taxpayer's registered address is affected by the administrative boundary changes pursuant to Resolution No. 1278/NQ-UBTVQH15 2024 related to the rearrangement of administrative units at the commune level for the period 2023-2025 in Ho Chi Minh City, whereby the address information on the taxpayer’s Business Registration Certificate is no longer appropriate, the Tax Department requests that enterprises re-register the information for using e-invoices and ensure the enterprise's address content on the e-invoice matches the address on the Business Registration Certificate.
Thus, enterprises are required to re-register the information for using e-invoices after changes to commune-level administrative divisions in Ho Chi Minh City and ensure the enterprise's address on the e-invoice matches the Business Registration Certificate's address.
Is it necessary to re-register the use of e-invoices after the administrative division change at the commune level in Ho Chi Minh City? (Image from Internet)
Where does the company issue e-invoices when the address has not been updated due to administrative boundary changes in Vietnam?
Based on Clause 4, Article 10 of Decree 123/2020/ND-CP, it is stipulated as follows:
Content of invoices
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- Name, address, and tax code of the seller
The invoice must display the name, address, and tax code of the seller as correctly indicated in the enterprise registration certificate, branch registration certificate, household business registration certificate, taxpayer registration certificate, tax code notification, investment registration certificate, or cooperative registration certificate.
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Hence, when issuing e-invoices, the company must issue the invoice with the correct address stated in the enterprise registration certificate, even if the company has not updated the address due to administrative boundary changes.
How to register changes in information for using e-invoices when changing administrative divisions in Vietnam?
Based on Clause 4, Article 15 of Decree 123/2020/ND-CP, it is stipulated as follows:
Registration, change of information registered for using e-invoices
...
- In cases of changes in the information registered for e-invoice use mentioned in Clause 1 of this Article, businesses, economic organizations, other organizations, households, and individual businesses shall make the necessary information changes and resubmit to the tax authority using Form No. 01/ĐKTĐ-HĐĐT Appendix IA, issued with this Decree, through the General Department of Taxation's e-portal or through an e-invoice service provider, except in cases of termination of e-invoice usage as stipulated in Clause 1, Article 16 of this Decree. The General Department of Taxation’s e-portal will accept the re-registration form and the Tax Authority will process it according to the provisions at Clause 2 of this Article.
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According to the above provision, to re-register information for using e-invoices when administrative divisions change, businesses must update the information and resubmit it to the tax authority using Form No. 01/ĐKTĐ-HĐĐT Appendix IA, issued with Decree 123/2020/ND-CP, via the General Department of Taxation's e-portal or through an e-invoice service provider.
