When a Vietnamese supplier's tax code status changes: what to do with contracts, invoices and input VAT

When a supplier's tax code status changes after you have started working with it, the first thing to do is stop and separate: hold new orders and payments, split the invoices you already hold into those issued before and after the change, and find out what the change actually means. A move to "temporarily suspended" at the supplier's own request is an administrative event. A move to 06 — not operating at the registered address or 03 — stopped operating without completing tax code termination is a signal that invoices from that supplier may be questioned, and that your input VAT and expense claims based on them need a second look.

Most finance teams check status once, at onboarding, and never again. This guide is about the rest of the relationship: how to notice a change, how to read it, what to do with each document already in your books and when to involve the supplier, your adviser or the tax office. It is written for accounts payable leads and controllers in foreign-invested companies, but the same steps apply to any buyer.

Why a status change matters to the buyer, not only the supplier

In Vietnam the buyer's tax position depends on the seller's invoices. Input VAT credit requires a lawful VAT invoice and, for purchases of VND 5 million or more, evidence of non-cash payment (Law 48/2024/QH15). Deductible expenses for corporate income tax also require lawful invoices and documents. If the tax authority later treats a supplier's invoices as unlawfully used — typically because the supplier was found not to be operating at its address when it issued them — the buyer's claims built on those invoices are exposed, even though the buyer did nothing wrong in its own books.

The rules on invoices sit in Decree 123/2020/NĐ-CP, amended by Decree 70/2025/NĐ-CP, and in Decree 254/2026/NĐ-CP on invoices and electronic documents, which took effect on 1 July 2026. We name them so you know where the detail lives; the practical conclusion does not change between them. The date on which the supplier's status changed, and the date of each invoice, are the two facts that decide most of what follows.

The status changes you will actually see

None of these entries tells you the supplier committed fraud or has tax debts. A status is a record of what the tax authority has observed, not a verdict. Your response should be proportionate: a suspension is paperwork; a 06 on a supplier you paid a large advance to last month is an urgent conversation.

Sorting invoices already in your books

Pull every invoice from the supplier for the open tax periods and sort them into three groups:

1. Issued before the status change, goods or services received and paid by bank transfer. These are the strongest. Keep the contract, delivery records, bank payment evidence and the original e-invoice file together, and confirm each invoice still appears correctly on the tax authority's e-invoice portal.
2. Issued before the change but not yet paid, or paid partly in cash. Pay only against verified delivery and only by bank transfer to the account in the supplier's registered name. Remember the non-cash payment condition for input VAT on purchases of VND 5 million or more.
3. Issued on or after the date the supplier was recorded as not operating. Treat these as the highest risk. Do not claim input VAT on them until you have understood the position; if you have already claimed, discuss with your adviser whether and how to adjust in the next return.

The effective date of a status change is not always obvious from the lookup screen. If it matters — and for invoices in the third group it does — ask the managing tax office in writing, or have your adviser do so, rather than guessing from the day you noticed the change.

Open purchase orders and payments still due

Freeze new purchase orders as soon as a 06 or 03 status appears. For goods already in transit, receive them with extra care: count, inspect and document delivery, because physical evidence of the transaction is what separates a genuine purchase from an invoice-only one.

For amounts still owed, two rules keep you out of trouble. Pay only into a bank account held in the supplier's registered name, never into a personal account or a third party's account on the supplier's instruction. And pay only against deliveries you can prove. A supplier whose status has changed will sometimes ask for payment to a different account "while the paperwork is sorted out"; that request should go to someone senior before anyone acts on it.

If the contract has a termination or suspension clause linked to the supplier's legal standing, now is the time to read it. Many template contracts used by foreign groups in Vietnam say nothing about tax status; adding a clause that requires the supplier to notify status changes and allows the buyer to suspend payment is a cheap improvement for the next renewal.

When the status change is on the customer side

The same register tells you about your customers. A customer moving to 03 or 06 raises a different question: will you be paid? The status does not answer it, but it justifies tightening terms immediately — stopping further credit, asking for payment before delivery, and chasing overdue balances.

For accounting and tax, an unpaid balance from a customer that has stopped operating does not become a deductible bad debt simply because the status changed. Provisions and write-offs are deductible only when made under the conditions set by the finance regulations, which require evidence such as overdue documentation and recovery efforts. Start collecting that evidence now, dated and in writing, rather than at year end.

Keep issuing invoices correctly for any deliveries you still make. Your own invoice obligations do not change because the buyer's status did.

Noticing changes without checking every supplier every week

A large supplier list cannot be looked up by hand every week. What works in practice:

• Tier the list. Re-check the top suppliers by spend, and any supplier receiving an advance, before each payment run. Re-check the long tail quarterly.
• Add a gate to the payment run. A supplier whose status has not been checked within the set period is held automatically until someone checks it.
• Watch for secondary signals. Returned mail, a new bank account, an invoice from a different branch code, a sudden change of legal representative. None is proof of anything; each is a reason to look up the code again.
• Record every check. Date, code, status, who checked. This record is part of showing good faith if an input VAT claim is ever questioned.

Expect more movement than usual in 2026. The tax authority's clean-up campaign under Official Dispatch 18/CĐ-CT of 13 July 2026 started from a review list of 617,462 enterprises (the July 2026 list), which means statuses across the register are being updated in bulk. For more on reading individual status codes, see TraThue.com (in Vietnamese).

If it is your own company's status that changed

Occasionally the surprise is internal: a subsidiary that moved office without updating its registration is recorded as 06 after a verification visit, or a dormant entity is caught in the clean-up campaign. The consequence can be serious — customers who check your code will see the status and may stop paying invoices until it is resolved.

The fix is procedural. Confirm the status and its date through the company's e-tax account and the taxpayer lookup, contact the managing tax office, bring filings and registration details up to date, and complete the procedure to restore the tax code where it applies. Decree 252/2026/NĐ-CP (guiding the Law on Tax Administration) and Circular 90/2026/TT-BTC (tax registration) are the current documents for these procedures; read them, or ask your adviser to, for the exact steps and forms. Meanwhile, tell key customers what happened and when you expect it resolved — silence costs more than the explanation.