Vietnam: No Separate Cancellation Notice Needed for Unused E-Invoices After Tax ID Termination

The Đắk Lắk provincial tax authority said that after a tax identification number ceases to be valid, unused electronic invoices are automatically locked in the tax system in line with the tax ID’s status, and the entity need not submit a separate cancellation notice. The response addressed an entity that had omitted the notice for unused electronic invoices while completing tax ID termination procedures following a merger.

The entity’s accountant, Nguyễn Thị Ngà, asked whether it could face an administrative penalty because electronic invoices remained unused after the tax authority decided to terminate the entity’s tax ID, and how it should complete the procedures. The Đắk Lắk provincial tax authority said it had issued a notice terminating the entity’s tax ID on October 23, 2026. The system then automatically stopped receiving its invoice data and issuing electronic invoice codes to it.

The response cited Article 8 of Vietnam’s Ministry of Finance Circular No. 91/2026/TT-BTC, issued on June 30, 2026: Organizations and other taxpayers must stop using electronic invoices after their tax IDs cease to be valid, and the tax administration system stops receiving the relevant electronic invoices from the date of termination. Article 13 of Circular No. 90/2026/TT-BTC also provides that a tax ID may not be used from the date the tax authority announces its termination. A terminated organization’s tax ID may not be used again unless it is restored.

The Đắk Lắk provincial tax authority therefore concluded that the entity’s unused electronic invoices could no longer be used and that no cancellation notice was required. Notice No. 2938/TB-DLA, issued by the authority on October 23, 2026, stated that the entity had fulfilled its tax obligations.

Source: VietVance