Accommodation services: Invoice when the online booker is not the guest

Khanh Hoa Provincial Tax Authority has issued Official Letter No. 4430/KHH-QLDN1 (August 2026) in response to a hotel business in Nha Trang on a situation common across the hospitality sector: a customer books and prepays a room through an online platform, but the person who made the booking is not the person who actually uses the service.

The guidance applies the new rules of Decree No. 254/2026/ND-CP (effective from 1 July 2026) and is relevant to every accommodation provider selling rooms through intermediary channels.

1. Time of invoice issuance where payment is collected in advance

Under Clause 2, Article 9 of Decree No. 254/2026/ND-CP dated 30 June 2026, the time of invoice issuance for the provision of services is the time the provision of services is completed (including services provided to foreign organizations and individuals), regardless of whether payment has been collected.

Where the service provider collects payment before or during the provision of services, the time of invoice issuance is the time of payment collection.

This rule excludes deposits collected under the Civil Code to secure the performance of a service contract.

2. Buyer information on the invoice

Point 4 of the Appendix on invoice contents issued with Decree No. 254/2026/ND-CP governs the name, address, tax code or budget-relation unit code, or personal identification number of the buyer. Sub-point (b) provides that:

• Where the buyer is a consumer who provides a name, address, and personal identification number, the invoice must show this information. For foreign buyers, the address and personal identification number may be replaced by the passport number or immigration document number and the customer's nationality.
• Where the buyer does not provide a name, address, or personal identification number, the invoice must clearly state "Sold to consumer".
• In certain specific cases of selling goods or providing services to individual consumers listed in Point 9 of the Appendix, the invoice is not required to show buyer information.
• An invoice without buyer information, or an invoice issued to a consumer, is not valid for economic organizations, agencies, other organizations, business households or business individuals to use for expense recording or tax finalization purposes.

Note: The list of specific cases in Point 9 of the Appendix (for example, petrol sold to individuals; stamps, tickets and cards) does not include accommodation services; hotels are therefore not exempt from showing buyer information where the guest has provided it.

3. The tax authority's conclusion for online bookings

Khanh Hoa Provincial Tax Authority provides guidance for the following situation: a hotel sells accommodation services through an online booking platform; the person who books and prepays is one person, while the person who actually stays is another. In this case, the e-invoice must show the full name and personal identification number of the actual guest - taken from the information the guest provides when registering their stay at the hotel - in accordance with Point 4 of the Appendix on invoice contents issued with Decree No. 254/2026/ND-CP.

The tax authority requests that the enterprise review its actual operations and the relevant legal instruments to ensure compliance.

💡 Recommendations for enterprises

• Review the room-sales process on online booking platforms: determine clearly whether the amount received in advance is an advance payment or a deposit under the Civil Code, as this determines the time of invoice issuance.
• Design a process to collect the full name and personal identification number (or passport and nationality for foreign guests) of the actual guest at the check-in registration step and link this data to the e-invoicing software.
• Update the invoicing software so that the buyer information field can correctly display "Sold to consumer" where the guest does not provide their details.
• For different real-life scenarios (group bookings, corporate customers paying through a platform), consider submitting a written request for guidance to the directly managing tax authority to mitigate risk.

This newsletter is prepared by Crowe Vietnam for general information purposes only and does not constitute advice for any specific case. Enterprises should refer to the original legal instruments and consult professional advisors before applying the above to their particular circumstances.