Tax experts raise concerns over new invoice rules for household businesses

The government's Decree 70 on invoices, effective from June 1, marks an important step forward in tax administration, but its impact on the business environment - especially on small household businesses - has raised some concerns.

The impact of Decree No. 70/2025/ND-CP, which amends and supplements Decree 123/2020/ND-CP, is one of the most debated topics at a seminar held by the Vietnam's Association of Foreign-Invested Enterprises (VAFIE) on Friday. The event seeked to update VAFIE member companies with legal developments in the country.

Participants acknowledged that the decree’s objectives are justified as bringing household businesses into a transparent, strict tax management framework is an inevitable trend, helping tax authorities to rein in frauds and ensure fairness. But some experts expressed concern over implementation challenges.

Nguyen Viet Ha, vice chairwoman of AmCham Hanoi, said that for the first time ever, she has seen a tax policy applied to a section of domestic businesses have such broad and deep impacts on foreign-invested enterprises, especially consumer goods producers.

"Many FDI companies have seen revenues sharpy drop in the last months since Decree 70 came into effect, because their distribution systems largely rely on small household businesses," she told the seminar.

Ha noted that the policy itself is justified in the long term as it is necessary to bring the group of household businesses into the tax management system in a more transparent way to support tax authorities.

"But we are very concerned that the policy is being implemented without enough time for household businesses to respond immediately. The impact is not only on those household businesses but also on manufacturing enterprises whose distribution channels are business households," she added.

Ha also proposed the upcoming adjusted Law on Tax Administration make it clear that the provisions on invoices for household businesses are non-retroactive.

According to a survey by the Vietnam Chamber of Commerce and Industry (VCCI) in July 2025, nearly 90% of household businesses are still unclear about their obligations regarding e-invoices from cash registers.

Specifically, 11.4% said they “fully understand” the rules, while 67.9% only have a “basic” understanding or are “unsure how to comply”. Up to 20.7% have no understanding at all or do not know how to implement.

Support from tax authorities remains limited. Over 50% of households have never received guidance, and only 14.2% have received detailed instructions.

As a result, the new regulations unintentionally become an administrative burden for small household businesses. Therefore, experts and enterprises have proposed several adjustments.

The proposed adjustments are a minimum one-year transition period with no penalties at the beginning; raising the revenue threshold for mandatory e-invoices connected to tax authorities from VND1 billion ($37,860) to VND2-3 billion/year; allowing small retailers (grocery shops, food stalls...) to use simplified invoices without immediate connection requirements; introducing tax exemptions/reductions for the first 6-12 months and supporting households with affordable software and cash register equipment, particularly for vulnerable groups.

Decree 70 is a significant advancement in tax administration, promoting transparency, preventing tax revenue loss, and aligning with the digital transformation trend. However, its effects on business life, especially small household businesses, require timely solutions.

In discussions on the draft Law on Tax Administration, some experts pointed out that requiring household businesses to both issue e-invoices and maintain input accounting books places a heavy burden on them, since they lack professional accounting staff.

Many households reported higher costs from hiring accounting services, complicated procedures, and higher risks of compliance or recording errors, leading to potential penalties.

International experiences

Japan allows small businesses to use simplified invoices without requiring detailed accounting records. Singapore applies a simplified accounting regime, requiring only basic record-keeping for inspection purposes.

Based on these examples, experts recommended allowing e-invoices to substitute for accounting books and stipulating clearly that issuing and storing e-invoices meet tax management requirements, so small businesses need not maintain additional input records.

They also proposed applying a simplified accounting regime for small businesses (e.g., with annual revenue below VND3 billion), requiring only storage of input/output invoices, simple revenue logs based on tax authority templates, and no detailed financial statements.

"Amending the Law on Tax Administration must follow the spirit of administrative reform: minimizing forms and avoiding duplication between e-invoices and accounting books so that household businesses can comply easily while tax authorities still have sufficient data to manage,” said a VAFIE tax expert.