Uni 14-07-2025 - Regarding the use of business address information after changing administrative areas

Official letter 2376/CT-NVT regarding the use of business address information after changing administrative areas as follows:

Pursuant to Clause 4, Article 6 of Decree No. 123/2020/ND-CP dated October 19, 2020 of the Government (amended by Clause 7, Article 1 of Decree No. 70/2023/ND-CP dated March 20, 2025).

According to the guidance in Official letter no. 4370/BTC-DNTN dated April 5, 2025 of the Ministry of Finance, enterprises, business households, cooperatives, cooperative unions, and cooperative groups shall continue to use the issued Certificate; The business registration authority shall not request enterprises, business households, cooperatives, cooperative unions, and cooperative groups to change address information due to changes in administrative boundaries. Enterprises, business households, cooperatives, cooperative unions, and cooperative groups must update information about their addresses due to changes in administrative boundaries on the Certificate when needed or at the same time when registering/notifying changes.

On the part of the Tax Authority, in order to meet the requirements of tax management according to the administrative areas at the provincial and communal levels, the Tax Department issued Official letter no. 1689/CT-NVT dated June 10, 2025 on reviewing and standardizing the taxpayer directory according to the 2-level administrative areas. The Tax Authority will proactively update tax registration information about the taxpayer's address on the tax industry's application system based on the decision to organize a new administrative unit by the competent authority, and at the same time notify the taxpayer without requiring the taxpayer to carry out the change procedure with the tax authority. The address information of the taxpayer according to the 2-level administrative areas will be synchronized for all applications of the tax industry, or automatically updated by the e-invoice solution provider on the e-invoice system provided to the taxpayer. Based on the above regulations and instructions, the implementation of updating 2-level localities on the tax sector database, the Tax Department has the following comments on updating address information on invoices:

The taxpayer's address determined according to the valid Business Registration Certificate and the address updated by the tax authority according to the 2-level administrative localities are both legally valid for use on invoices. Therefore:

1.  Incase the enterprise (buyer or seller) is subject to inter-registration with business registration and continues to use the Business Registration Certificate with the old address (address before the change of administrative boundaries) according to the instructions in Official letter no. 4370/BTC-DNTN:

a) In case the business address information has been updated by the tax authority according to the corresponding 2-level administrative area and this information has been synchronized to the electronic invoice system, the address information on the invoice is the address information that has been updated by the tax authority. Taxpayers use the tax authority's notification to provide information to relevant agencies or customers in case only the invoice states that the address has been updated according to the new administrative area list but the information on the Business Registration Certificate is still the address according to the old administrative area list.

b) In case the business address information has been updated by the tax authority according to the corresponding 2-level administrative area but has not been synchronized to the electronic invoice system, the address information on the invoice is the address information on the Business Registration Certificate.

2. In case the buyer is not subject to registration linked with business registration, the address stated on the invoice is the address updated by the tax authority according to the 2-level administrative area on the tax industry's application system.