The Vietnam Chamber of Commerce and Industry (VCCI) has just sent a document to the Ministry of Finance of Vietnam providing comments on the draft Decree amending and supplementing Article 9 of Decree No. 123/2020/ND-CP (Decree 123) on invoices and documents (Decree 123 was previously amended and supplemented by Decree No. 70/2025/ND-CP).

Based on a compilation of opinions from the business community, VCCI said there remain obstacles related to issuing invoices for ride-hailing platforms whose customers are organizations and enterprises using services under a “use first, pay later” model with periodic payment.

According to VCCI, although this model has a large transaction volume, occurs frequently, and requires data reconciliation — which already meets the conditions for issuing invoices according to an agreed period — Decree 123 and the current draft still have not listed the applicable sectors. This forces platforms to issue millions of individual invoices, causing a sudden increase in data costs and overloading the systems of both enterprises and tax authorities.

VCCI recommends adding the activity of “passenger transport services using software to support transport connection” provided to organizational customers to the category eligible for issuing invoices by period. At the same time, the organization also proposes allowing contract vehicles and two-wheeled motorbike services using technology applications to issue consolidated invoices at the end of the day for individual customers, similar to the traditional taxi model.

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Commenting on regulations related to electronic invoices of business households, VCCI said the requirement that invoices must include the buyer’s tax code or personal identification number is creating significant difficulties for retail, food and beverage, and accommodation sectors.

The characteristics of this group are a large number of retail customers, small transaction values, and fast transaction times. Requiring identification information not only increases cashier labor costs but also creates discomfort for consumers.

VCCI proposes allowing electronic invoices of business households not necessarily to include the buyer’s tax code or personal identification number if the buyer is a non-business individual, in order to ensure consistency with exemption policies currently applied to supermarkets and fuel stations.

The current draft allows consolidated invoices to be issued at the end of the period for buyers who are non-business individuals. However, enterprises reported that it is very difficult to distinguish which individuals are conducting transactions for business purposes or personal consumption if they do not voluntarily provide information.

The inability to accurately identify the subject leads to the risk that enterprises may be administratively penalized for issuing insufficient invoices. To remove this bottleneck, VCCI proposes that the drafting agency add specific guidance: individuals should be presumed to be non-business if they do not request an invoice at the time the transaction arises.

According to VCCI, revising these regulations is very necessary to reduce compliance burdens while ensuring transparency without creating risks of tax revenue loss, as platforms and enterprises currently declare and pay taxes on behalf of users fully in accordance with legal regulations.