Currently, e-invoices are considered one of the biggest successes of the digital transformation process in the field of taxation in Vietnam. The e-invoice system not only helps management agencies improve the efficiency of supervision and prevent budget revenue loss, but also helps businesses save costs, reduce administrative procedures and increase transparency in business activities.
Source: Government News
However, along with the expanding scope of application and increasingly stringent management requirements, e-invoices and e-documents are also becoming one of the biggest sources of compliance risk for businesses. In fact, many businesses are subject to tax arrears, administrative sanctions or difficulties in accounting and deducting taxes just because of seemingly very small errors related to invoices.
It is worth noting that the Draft Decree regulating e-invoices and electronic documents to guide the Law on Tax Administration No. 2025 (Draft) being consulted by the Ministry of Finance[1] continues to show the trend of management in the direction of comprehensive digitalization, strengthening data connectivity and improving the responsibility of taxpayers. If businesses do not prepare early, e-invoices can completely become one of the biggest compliance pressures in business activities.
When invoices are no longer just an accountant's story
In traditional thinking, invoices are often seen as the work of the accounting or finance department. However, in the modern management environment, e-invoices have become an important link in the entire operation chain of businesses.
The information on the invoice is directly related to contracts, freight forwarding, ERP systems, sales systems, customer data, warehouse data, payment data, and also tax administration activities. As long as one link in this chain goes wrong, the risk can spread to many different fields.
For example, a small discrepancy in the timing of an invoice can result in the recording of revenue on an irregular basis, incurring a discrepancy between accounting revenue and tax declaration revenue. An error in the customer tax identification number may affect the buyer's ability to deduct taxes. An invoice that is made improperly can cause all related expenses to be excluded when finalizing taxes.
Therefore, managing e-invoices today is no longer an accountant's own task but has become a part of the business compliance management system.
The new draft shows the trend of increasingly tight management
According to the Ministry of Finance, after more than three years of officially implementing e-invoices nationwide, the system has recorded positive results with billions of invoices being processed and stored on the management system of the tax authority. However, the practice also arises many new problems that require adjustment of the current legal framework.
One of the important orientations of the draft is to strengthen management based on digital data. This is reflected through the completion of regulations on connection, data transmission, data storage, information retrieval and responsibilities of parties involved in the e-invoice ecosystem.
For businesses, this means that tax authorities will be able to collate, analyze and detect abnormal signs much faster than before.
In an interconnected data environment, discrepancies between invoice revenue, tax return revenue, banking data, e-commerce data, or data from other agencies are easier to identify.
In other words, the room for errors or omissions in invoice management is shrinking.
Changes that businesses need to pay special attention to
Firstly, expanding the scope of regulation and subjects of application
The draft continues to improve regulations related to organizations and individuals participating in business activities in the digital environment, e-commerce and digital platforms. A number of new regulations have also been added for foreign organizations doing business on e-commerce platforms or digital platforms that incur tax obligations in Vietnam.
This reflects the trend of tax management that is shifting from a record-based management model to management according to the actual transaction data flow.
Second, tighten regulations on the time of invoicing
The time of invoicing is always one of the most disputed contents in reality.
The draft continues to supplement and clarify many specific cases related to the time of invoicing for goods, services, e-commerce, telecommunications, transportation, insurance, banking, lotteries and many other industries.
For businesses, this is an issue that needs special attention because errors in the time of invoicing often lead to a series of consequences such as: (i) Declaring revenue in the wrong period; (ii) Declaring VAT at the wrong time; (iii) Being administratively sanctioned; (iv) Disputes arise with customers; (iv) Having difficulties in tax finalization.
In the context of tax authorities being able to reconcile data in real time, delays or incorrect invoicing at the right time will be increasingly difficult to ignore.
Third, strengthen the management of invoices generated from cash registers
Another noteworthy point is that the draft continues to improve the management mechanism for e-invoices generated from cash registers connected to data with tax authorities.
This type of invoice is designed for sectors with high transaction frequency such as retail, catering, supermarkets, hotels, shopping malls or consumer service industries.
The expansion of the application of invoices from cash registers helps increase transparency but also requires businesses to invest in appropriate information technology systems, ensuring that data is transmitted fully and accurately.
Fourth, improve the responsibility for data storage and security
With traditional papers, storing invoices is often just a matter of storage space. In the digital environment, the problem has changed completely.
Enterprises must not only keep invoice data but also ensure the integrity, traceability, accuracy and ability to provide data when requested by state agencies. The draft devotes many regulations related to the preservation, storage, exploitation and use of e-invoice data and e-documents.
This means that IT risks, data loss, system failures or security vulnerabilities can become tax risks.
Source: Government News
Common mistakes that cause businesses to be sanctioned
Through the practice of tax consulting and inspection, it can be seen that some groups of errors appear very frequently.
The first is invoicing at the wrong time.
Many businesses still have the habit of waiting for payment to be completed before issuing invoices or accumulating many transactions to issue invoices at the end of the month. In many cases, this practice is not in accordance with the law on invoices.
The second is that the information on the invoice does not match the transaction records.
Discrepancies in the name of the goods, unit of calculation, quantity, customer address or tax identification number are small but can lead to significant controversies when inspected by the tax authorities.
The third is distributed management.
Many businesses use many different software for sales, warehousing, accounting and tax but lack a data synchronization mechanism. As a result, the data between the systems is not consistent.
The fourth is to underestimate archiving.
Some businesses only store data at the software provider without a standalone backup mechanism. When technical problems or disputes arise, businesses may have difficulty proving the legality of the documents.
Shifting from an "invoicing" mindset to a "data governance" mindset
One of the biggest changes that businesses need to make is to change their approach to e-invoices.
In the early stages of digital transformation, businesses mainly focus on replacing paper invoices with electronic invoices. An e-invoice is actually a legally valid data set. Its value does not lie in the invoice but in its ability to connect to the entire data system of the business.
Therefore, instead of only paying attention to issuing invoices, businesses need to build an invoice data management strategy. Accordingly, businesses should standardize the invoicing process; data connection between systems; establish an automatic inspection and reconciliation mechanism; develop data storage and backup policies; periodic assessment of compliance risks; in particular, it is necessary to pay attention to the issue of related personnel training.
When invoices are considered part of the enterprise data management system, the risk of errors is significantly reduced.
In the context that the Draft Decree is being finalized and the trend of data-based tax management is becoming clearer, businesses should proactively and comprehensively review their e-invoice system.
First of all, it is necessary to re-evaluate the current process of issuance, management and storage of invoices to identify potential weaknesses.
Next, it is necessary to review the compatibility between the software being used to ensure that the data is synchronized and consistent.
At the same time, businesses should periodically check high-value invoice records or high-risk transactions to detect errors early.
Finally, e-invoice management should be considered as a part of the overall tax compliance program rather than just an administrative task of the accounting department.
The development of e-invoices is an inevitable trend in the digital economy. However, along with the benefits it brings are increasingly high compliance requirements and an increasingly tight level of oversight by regulators. The new draft Decree on e-invoices and e-documents continues to affirm the orientation of data-based management, strengthening information connection and enhancing the responsibility of taxpayers. For businesses, the question is no longer whether to use e-invoices or not, but whether they have the capacity to effectively manage e-invoice data. If managed properly, e-invoices will be an effective support tool for business management and development. Conversely, if overlooked, it could become one of the biggest sources of compliance risk that businesses face in the coming years.
