In a draft Decree detailing tax declaration, calculation, deduction, payment, and use of e-invoices for business households and individual businesses (collectively referred to as business households), the Ministry of Finance proposes that business households with annual revenue of VND1 billion or more use e-invoices with tax authority codes or e-invoices initiated from cash registers with data connection to tax authorities as prescribed in the government’s Decree 70/2025.

According to the Vietnam Chamber of Commerce and Industry (VCCI), setting the threshold aims to enhance transparency and combat tax fraud. However, the VND1 billion revenue threshold appears inappropriate. This threshold does not align with revenue thresholds currently used in tax calculation methods, which are VND3 billion and VND50 billion.

“This is a relatively low revenue level, only VND500 million higher than the tax-exempt threshold, while the financial capacity and management capability of many household businesses at this level remain limited,” VCCI noted.

A rapid survey conducted by VCCI in June 2025 found that household businesses with revenue above VND1 billion still face many difficulties in implementing e-invoices connected to the tax authority. 

Specifically, 32 percent in rural areas and 23 percent in urban areas lack investment capital, while 77 percent in rural areas and 67 percent in urban areas lack technological knowledge and skills.

VCCI acknowledged that e-invoices authenticated by the tax authority is necessary, but  the system must be designed to avoid placing additional pressure on small-scale household businesses.

VCCI proposed raising the annual revenue threshold for applying e-invoices to above VND3 billion, corresponding to the threshold for starting to apply the profit-based tax calculation method. 

For business households with revenue below this threshold, tax authorities can strengthen supervision through data collected from many sources instead of requiring simultaneous application.

Nguyen Ngoc Tu, a lecturer at Hanoi University of Business and Technology, said the application of e-invoices to household businesses has already been stipulated in Government Decree 70/2025, and the current draft mainly reiterates this provision to ensure consistency.

Tu believes that the regulation that the annual revenue threshold of VND1 billion proposed by the Ministry of Finance is reasonable. It is actually not large, especially when placed in correlation with the current tax management scale.

He said that out of a total of about 5.2 million business households nationwide, only more than 37,000 households have revenue over VND1 billion per year, accounting for less than 1 percent. 

Meanwhile, the overall policy is to proceed with applying invoices to all enterprises to serve the goal of digital economic development and enhance publicity and transparency.

According to Nguyen Ngoc Tu, if the revenue threshold is raised to VND3 billion before mandatory e-invoice application, it might seem reasonable in terms of scale, but in reality, it will lead to the consequence that almost the entire individual business sector will not use invoices or documents. 

This could cause the non-invoice economy and informal economy to “swell”, negatively affecting other economic sectors.

He argued that, in the short term, at a minimum, household businesses with annual revenue of VND1 billion or more should be required to apply e-invoices, while gradually expanding application to household businesses with revenue below VND1 billion.

Nguyen Ngoc Tinh, vice chairman of the HCMC Association of Tax Consultants and Agents, said that under the second draft, there is only one method for calculating value-added tax, namely the direct method based on revenue. Under this method, sales invoices must be used. According to the Value-Added Tax Law, household businesses are not subject to using value-added tax invoices.

“If household businesses with revenue of VND1 billion or more are required to use e-invoices, while those with revenue above VND500 million and below VND1 billion are not required to use e-invoices, how can value-added tax obligations be determined?” Tinh asked.

He noted that the 2024 Value-Added Tax Law defines “revenue for value-added tax calculation as the total amount from the sale of goods and services recorded on sales invoices, including surcharges and additional fees that the business entity is entitled to receive.”

As for household businesses with revenue below VND500 million, which fall under the non-taxable category, the draft stipulates that once revenue reaches VND500 million, tax declaration must be made no later than the 30th day of the first month of the following quarter. “So what documentation is used as the basis to determine revenue for this group?” Tinh said.

Nguyen Le