According to the VCCI, the requirement for business households and individuals with annual revenue from VND1 billion (US$38,000) to use e-invoices created from cash registers electronically connected to the tax agency, as regulated in Decree 70/2025/ND-CP, is appropriate. It poses significant challenges, especially due to limited tech knowledge and difficulty in changing traditional management habits.
In order to create favorable conditions for businesses to adapt with the new context and to support sustainable revenue, the VCCI recommends exempting these entities from administrative penalties for formal violations during the first two years.
The VCCI also proposes amending current penalty regulations to treat multiple invoice violations occurring on the same day as part of a single inspection, thus avoiding unfair penalty escalations. Additionally, it suggests grouping violations on the same invoice if they are merely technical errors without signs of tax fraud.
For late invoice issuance due to technical errors that don’t affect tax obligations, the VCCI recommends only issuing warnings or applying the lowest fines.
Notably, the VCCI suggests not penalizing businesses for not issuing invoices if they have already been penalized for underreporting tax due to incorrect declarations.
As for banks, the VCCI recommends including exceptions in cases where tax cannot be deducted from taxpayers’ accounts due to force majeure circumstances.
