Official Letter No. 1591/CT-CS dated June 5, 2025 introduces the new provisions of Circular No. 31/2025/TT-BTC and Circular No. 32/2025/TT-BTC issued by the Ministry of Finance.

Circular No. 31/2025/TT-BTC

Circular No. 31/2025/TT-BTC amends and supplements certain provisions of Circular No. 23/2021/TT-BTC, which provides guidance on the printing, issuance, management, and use of electronic stamps for alcohol and tobacco products. Notable new provisions include:

• Submission of applications and use of electronic stamps: The tax administration procedures information system will automatically issue notifications for Forms No. 04/TEM and 07/TEM.
• Cases where electronic stamps are no longer valid: Additional provisions are introduced for lost, burnt, or damaged electronic stamps, requiring organizations and individuals to report such incidents via the tax administrative procedure system. The tax authority is no longer required to issue a separate notice declaring the stamp invalid.
• Purchase of electronic stamps: The requirement for organizations and individuals to submit various documents when visiting tax authorities to purchase or receive stamps has been eliminated.
• Information embedded in the QR code of electronic stamps:

Additional regulations require that, upon issuing stamps to the production department, organizations and individuals must scan the QR code and input relevant data such as the product name, production time, unit of measurement (liters/cigarettes), and selling unit price. This process ensures that electronic stamp data is integrated with the Electronic Stamp Management System.

Users and relevant authorities may look up stamp information via the Tax Sector's electronic information portal, including the type of stamp, sample code symbol, stamp code; name and tax identification number of the manufacturing entity; name of the tax authority selling the stamp, date of sale; product name; production time; unit of measurement; and selling unit price.

• Handling of electronic stamps in cases of production cessation, dissolution, bankruptcy, division, separation, merger, or change of tax authority:

Enterprises are required to conduct a final settlement and destroy any remaining electronic stamps within 5 working days from the date of notification of production cessation or from the date of the decision on dissolution, bankruptcy, or merger.
In cases of division, separation, merger, or change of the directly managing tax authority, if there is a need to continue using the remaining stamps, enterprises must register for adjustments via the Tax Administration Procedures Information System.

• Handling of damaged electronic stamps:

Regulations are provided regarding the destruction of damaged electronic stamps in storage or during the production process (e.g. torn, blurred characters, or fragmented stamps). In cases where stamps have already been affixed to products and reported as used but are subsequently damaged during distribution or when the product is destroyed, the enterprise must also destroy the electronic stamps.

Organizations and individuals are required to submit a notification of the results of the stamp destruction via the Tax Administration Procedures Information System no later than 5 working days from the date of destruction, using Form No. 04/TEM.

• Stamp printing costs:

The selling price of stamps shall be determined based on the principle of fully covering stamp printing costs and tax obligations.

• Replacement and abolition of forms:

Form No. 02/TEM, 04/TEM, and 07/TEM under Circular No. 23/2021/TT-BTC are replaced with corresponding new forms, and Form No. 03/TEM and 05/TEM are abolished.

Circular No. 32/2025/TT-BTC

Circular No. 32/2025/TT-BTC provides guidance on certain matters related to invoices and documents in accordance with the Law on Tax Administration, Decree No. 123/2020/NĐ-CP, and Decree No. 70/2025/NĐ-CP. The main contents include:

• Incentives to encourage consumers to request invoices:

The Tax Department shall utilize the electronic invoice database to develop and implement a “lucky invoice” program for electronic invoices where the buyer is a consumer.

• Authorization for electronic invoice issuance:

Supplementary regulations require that electronic invoices issued by authorized parties must be consistent withthe tax calculation method of the authorizing party. The authorization agreement must include information about both the authorizing and authorized parties.
In cases where household businesses or individual business households authorize e-commerce platform operators to issue invoices on their behalf, the platform operators must notify the tax authority.

• Invoice form codes, invoice symbols, and invoice copy names:

Additional invoice form codes are introduced, including code No. 7 for e-commerce invoices, code No. 8 for value-added electronic invoices integrated with receipts for taxes, fees, and charges, and code No. 9 for sales electronic invoices integrated with receipts for taxes, fees, and charges. The character "X" is added as a symbol for e-commerce invoices.

• Application of electronic invoices to other specific cases:

Electronic invoicing is extended to include the sale of derivative products, provision of industrial meal services, services of commodity exchanges, credit information services, and passenger transportation services by taxi (for customers that are enterprises or organizations). Additional guidance is provided for invoice issuance by financial leasing institutions.

Five additional criteria have been introduced for identifying high-risk taxpayers when registering for the use of electronic invoices::

 1. The taxpayer has an owner or legal representative who has been concluded by a competent authority to have committed invoice fraud or engaged in the buying and selling of invoices.

2. The taxpayer has an owner or legal representative listed in suspicious transaction reports under the Law on Anti-Money Laundering.

3. The taxpayer registers a head office address that is either non-specific, located in a residential apartment not permitted for business use, or at a business location outside the registered province/city.

4. The taxpayer has a legal representative or owner who falls under the status of “Taxpayer has ceased operations but has not completed tax code termination procedures” or “Taxpayer is not operating at the registered address,” or who has committed violations related to taxes, invoices, or documents.

5. The taxpayer shows other signs of tax risk as determined and notified by the tax authority.

• Use of documents:

The Sub-Department of Taxation shall generate electronic tax receipts using Form CTT50 for the collection of agricultural land use tax and non-agricultural land use tax from households and individuals.

• Criteria for organizations providing e-invoice solutions and related services:
  The Tax Department will publish a list of qualified organizations that fully meet regulatory requirements on the Tax Department’s electronic information portal, instead of the tax authority selecting service providers for direct connection of e-invoice services.
• Effective date:

This Circular takes effect on June 1, 2025, and replaces Circular No. 78/2021/TT-BTC.
From the effective date of Decree No. 70/2025/NĐ-CP, organizations responsible for personal income tax withholding must cease using previously applied electronic personal income tax withholding documents and switch to implementation in accordance with Decree No. 70/2025/NĐ-CP.

• Transitional provisions:

Household businesses and individual business households shall use electronic invoices generated from cash registers starting from the time the tax authority approves their registration for use.

Enterprises that have registered for the use of electronic invoices but have not yet complied with the standard data format required by the tax authority must register to use electronic invoices generated from cash registers.

If an invoice was issued incorrectly under previous regulations, the seller and the buyer must prepare a written agreement and issue a new replacement electronic invoice, containing the phrase:

"This invoice replaces Invoice Form No.…, symbol…, No.…, dated…."

In cases where enterprises sell goods or provide services directly to consumers as specified under Clause 8, Article 1 of Decree No. 70/2025/NĐ-CP and have registered for electronic invoice use with the tax authority but the invoices do not yet carry the tax authority's code or are not in electronic data form, they must register to use cash register-based electronic invoices  in accordance with regulations.

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