Issuing invoices for vehicle repair services when the service buyer is not the registered vehicle owner

On 16 September 2026, Can Tho City Tax Authority issued Official Letter No. 8262/CTH-QLDN4 in response to a query from an automotive repair and maintenance service provider regarding cases where the party requesting an invoice is not the vehicle owner named on the Vehicle Registration Certificate. The tax authority confirms that the invoice must be issued to the party that actually purchases the service, based on the transaction records and supporting documents - not at the customer's request merely to serve their accounting or tax deduction purposes.

1. Legal basis cited by the tax authority

The Official Letter relies on Decree No. 254/2026/ND-CP dated 30 June 2026 of the Government detailing the Law on Tax Administration No. 108/2025/QH15 with respect to electronic invoices and electronic documents, specifically:

• Obligation to issue invoices - Clause 1, Article 4 of Decree No. 254/2026/ND-CP: when selling goods or providing services, the seller must issue an electronic invoice to the buyer, except for cases in which electronic invoices are not required under Article 7 of the Decree.
• Buyer information on the invoice - Point d, Clause 1, Article 10 of Decree No. 254/2026/ND-CP: the invoice must show the buyer's name, address, and tax code or budget-relation unit code or personal identification number. For electronic invoices generated from cash registers, the buyer's information (name, address, tax code/personal identification number/phone number) is recorded as prescribed if the buyer so requests - Point b, Clause 4, Article 10 of Decree No. 254/2026/ND-CP.
• How to record information of a buyer that is a business establishment - Sub-point a, Point 4 of the Appendix "Invoice Contents" issued together with Decree No. 254/2026/ND-CP: the buyer's name, address and tax code must be recorded exactly as stated in the enterprise registration certificate, branch operation registration certificate, household business registration certificate, tax registration certificate, tax code notification, investment registration certificate or cooperative registration certificate; where the buyer provides a budget-relation unit code, the code as issued is recorded.

2. Guidance for the two scenarios

Scenario 1 - The vehicle owner is also the service buyer: The enterprise issues the invoice to the organization or individual named on the Vehicle Registration Certificate in the ordinary manner.

Scenario 2 - The vehicle owner differs from the party directly purchasing the service: The enterprise may issue the invoice to the organization or individual directly purchasing the service, provided there is sufficient evidence that such party:

• is the party that actually entered into the contract and purchased the service;
• has the right or responsibility to use the vehicle and bears the repair and maintenance costs;
• directly carries out, or is responsible for, the transaction with the enterprise.

3. Overarching principle: the invoice must reflect the actual transaction

Invoices must be issued based on the actual transaction and the relevant records and documents, ensuring that the buyer information on the invoice matches the actual service buyer. The tax authority states clearly that the enterprise may not issue an invoice to an organization or individual other than the service buyer merely to meet the customer's accounting or input tax deduction requirements.

Can Tho City Tax Authority requests that the enterprise review each specific transaction against the actual records and documents to issue invoices in accordance with regulations. The enterprise is legally responsible for the accuracy and truthfulness of invoices issued under Decree No. 254/2026/ND-CP.

💡 Recommendations for enterprises

1. Identify the correct "service buyer" before issuing the invoice: rely on the service contract/service request form, the signatory and the paying party - do not default to the Vehicle Registration Certificate.
2. Retain supporting evidence when the buyer differs from the vehicle owner: vehicle lease/loan agreements, documents assigning the vehicle to an employee or a group company, authorization to use the vehicle, and payment vouchers from the buyer's account.
3. Decline requests to "invoice my company" where no supporting basis exists: the risk of an invoice issued to the wrong buyer rests with the seller under Decree No. 254/2026/ND-CP.
4. Cross-check the buyer's details against its enterprise/tax registration documents before issuing, in accordance with Sub-point a, Point 4 of the Appendix to Decree No. 254/2026/ND-CP.
5. For enterprises that lease or use vehicles owned by others: proactively prepare the above set of documents so that the repair shop has a basis to issue the invoice in the enterprise's name, ensuring the expense can be recorded and the input tax deducted.

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.