Newly-Established Household Businesses: E-Invoice Registration Rules and Allowable Expense Treatment for Buyers Before Invoice Availability
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The Ministry of Finance clarified for a household business established on 3 March 2026 two key questions: (1) when it may register and use e-invoices; and (2) whether payments made by a corporate buyer to the household business before e-invoices are available can be treated as allowable expenses for Corporate Income Tax (CIT) purposes. Under Articles 8 and 9 of Decree 68/2026/ND-CP: A newly-established household business must register for e-invoices within 30 days of the last day of the tax period in which cumulative VAT-taxable revenue reaches VND 1 billion. The household may only begin using e-invoices after completing registration with the tax authority. For the buyer's deductible expenses: Under Article 13 of Circular 20/2026/TT-BTC, corporate buyers purchasing from household businesses with sub-threshold VAT revenue may use Form 02/TNDN (a purchase declaration list, substituting for an invoice) to support deductible expense treatment, provided non-cash payment evidence exists for transactions of VND 5 million or more.
Ministry of Finance Guidance on E-Invoices and Allowable Expenses for Newly-Established Household Businesses
Key legal references: Decree 68/2026/ND-CP dated 5 March 2026; Circular 20/2026/TT-BTC dated 12 March 2026; Decree 320/2025/ND-CP; Law on CIT No. 67/2025/QH15
1. E-Invoice Registration and Usage Rules
For household business established 3 March 2026:
Under Article 8(5) and Article 9 of Decree 68/2026/ND-CP:
Revenue below VND 500 million (first 6 months):
- Not required to use e-invoices
- Must notify actual revenue to the tax authority by 31 July (for first-half activity) and 31 January of the following year
Revenue VND 500 million to under VND 1 billion per year:
- Not required to use tax-authority-coded e-invoices
- May voluntarily register if desired
- Without registration but needing an invoice: must declare and pay tax before the tax authority issues a per-transaction coded e-invoice
Revenue VND 1 billion or more per year:
- Mandatory registration for tax-authority-coded e-invoices or POS-linked e-invoices
- Registration deadline: within 30 days of the last day of the tax period in which cumulative VAT-taxable revenue reaches VND 1 billion
- May use e-invoices only after completing registration
Conclusion: The household business is not at risk of penalty for not issuing invoices before completing proper registration per the above process.
2. Can the Corporate Buyer Deduct the Expense?
Under Article 9(1) of the Law on CIT No. 67/2025/QH15 and Decree 320/2025/ND-CP, expenses are deductible if:
- Actually incurred and related to business activities
- Supported by invoices and documents per regulations
- Supported by non-cash payment evidence (for transactions of VND 5 million or more)
For purchases from sub-threshold household businesses:
Under Article 13(3) of Circular 20/2026/TT-BTC: The corporate buyer may prepare a Purchase Declaration List (Form 02/TNDN), signed by the legal representative or authorised person, in lieu of a formal invoice, combined with non-cash payment documentation where individual daily transactions with the household business reach VND 5 million or more.