Tax Alerts & Risks
Invoices from a vanished supplier: how not to lose money
You did nothing wrong. You can still lose hundreds of millions because of someone else's invoice.
Quick summary
- If a supplier vanishes, its invoices in your books can be disallowed: you lose the VAT credit and the CIT deduction, plus 0.03% late interest per day.
- A real deal with a bad invoice is an incorrect filing: a 20% fine, or none if you fix it early. A deal you can't prove can become tax evasion: 1 to 3 times the tax.
- What saves you is a file where three flows match: documents, goods and money.
- Never buy a replacement invoice. That is the real tax evasion.
You did nothing wrong. You can still lose hundreds of millions, just because of someone else's invoice.
Sounds absurd, doesn't it? I used to think so too. Until I sat with more business owners than I can count, a tax office letter in their hands, asking me the same thing: "What did I do wrong?"
I'm the founder of Kaizen Accounting. I'm telling you this story because it happens every week. And the people caught in it are usually the most honest operators in the room.
A perfectly ordinary Tuesday morning
Your accountant puts a letter on your desk. The tax office wants an explanation for 14 input invoices. The reason: the supplier is "not operating at its registered address".
In plain words: they have vanished. You are still here. So are their 14 invoices, sitting in your books.
It's like buying a used car. The papers look fine, it drives well. Three months later, the previous owner's speeding tickets start arriving at your door.
If you remember one thing from this article, make it this: the tax office isn't asking whether you did something wrong. It's asking whether you can prove you didn't.
That's why, with every new client, the first thing Kaizen does isn't bookkeeping. It's a Tax Health Check: we go through every input invoice before the tax office does.
What invoices from a vanished supplier cost you
I always tell clients: numbers first, feelings later. Feelings don't lower your tax bill.
If the invoices are found to be unlawful, you don't lose one thing. You lose three, all at once.
- The input VAT you already credited. The Law on VAT No. 48/2024/QH15 only allows a credit backed by a lawful invoice. A "problem" invoice means paying it back.
- The expense for corporate income tax. Under Article 9.1(b) of Decree 320/2025/ND-CP, a cost needs proper invoices and documents. You spent the money, but on the return it never happened.
- Late interest of 0.03% per day on the extra tax (Article 16.2(a) of the Law on Tax Administration 108/2025/QH15). It runs on weekends and holidays too.
Let's do a quick sum. 14 invoices at 200 million each. 2.8 billion in total.
The credited VAT alone is around 280 million. Add CIT on the disallowed cost. Add interest that grows every day. That's several months of salary for an entire sales team.
Still think this is just your accountant's paperwork?
The frustrating part: most of this is far easier to handle when it's found early. That's exactly what an in-depth tax health check is for: find it first, so you act on your terms instead of being called out.
Two roads, worlds apart
This is the most important part. Please slow down with me for a moment.
Law 108/2025/QH15 doesn't treat every case the same. The same invoice can send you down one of two roads.
Think of two drivers in the same crash. One skidded on a wet road. The other was drunk. Same collision, two very different verdicts.
What decides whether you're the wet road or the drunk driver isn't the truth. It's the evidence of the truth. And evidence has to be prepared in advance, not hunted for once the questions start.
5 steps to handle invoices from a vanished supplier
Step 1: Map the exposure before you panic
Look up the seller's tax code on the tax authority portal. Status 06 under Appendix 1 of Circular 90/2026/TT-BTC means not operating at the registered address.
Note the date the status changed. List every invoice from them, period by period. Look hardest at invoices dated close to or after that date: they get questioned first.
Step 2: Build the three-flow file
Article 3.7 of Decree 254/2026/ND-CP treats invoices for transactions that never happened as unlawful. So your job is simple to state: show the transaction was real.
Switch seats for a second. If you were the tax officer, what would you believe? Not a story. Three flows that match:
- Documents: contracts, purchase orders, quotations, email exchanges.
- Goods: delivery notes, warehouse receipts, transport documents, acceptance minutes.
- Money: bank transfers into an account in the supplier's own name.
- And proof of use: stock on hand, issues to production, the matching sales invoices.
Missing one flow, your file is half as strong. Missing two, you're walking yourself onto road two.
In every Tax Health Check, we build this three-flow file for each major supplier in advance. So if the question ever comes, you just open the drawer.
Step 3: Reply on time, and properly
Under Article 22.2(b) of Law 108/2025/QH15, an unsatisfactory explanation lets the tax office assess the tax or move to an audit at your premises.
In other words: one careless reply can invite a whole audit team in. Write it in chronological order, number every attachment, and make every figure match your books to the last dong.
Step 4: Know when to stop arguing
Many owners don't like this step. I still have to say it.
If the evidence isn't there, self-correction is usually the cheapest route. Article 12.5 of Law 108/2025/QH15 allows a supplementary return within 5 years, as long as it's before an inspection or audit decision.
You reverse the input VAT, add back the cost, and pay the tax and interest. It hurts, but the pain has a floor. Fighting to the end without evidence has no floor at all.
Step 5: Lock the stable before the horse bolts
A risky invoice rarely comes alone. New suppliers, vague offices, suspiciously low prices, requests to pay a personal account. Sound familiar?
How many names like that are on your supplier list? If you can't answer right away, that is your answer.
The question you should really be asking
It isn't "how do I deal with these 14 invoices". It's: how many invoices like this are sitting quietly in my books?
You get a health check every year. Not because you feel ill. Because the most dangerous illness has no symptoms.
Books work the same way. An invoice from a vanished supplier doesn't hurt and doesn't make noise. It just waits for the day the tax office calls its name.
Kaizen Accounting's founders have more than 17 years in the profession, starting at Big4. We sat on the other side of the table long enough to know what the tax office asks, and which files hold up. Our Tax Health Check was built from those years.
What you can do today
Open the list of your 10 largest suppliers this year. Check each one's tax code status. It takes about 15 minutes, the length of a coffee.
All at status 00? Wonderful. You just bought yourself a good night's sleep.
One name looks wrong? Don't wait for the tax office's letter. An input invoice review with Kaizen today costs far less than a back-tax decision tomorrow.
And if you're not sure where to start, just message us. As I always tell clients: asking early is free, asking late is what costs money.
Frequently asked questions
Will I be fined for invoices from a supplier that vanished?
Possibly not. If the goods and money were real, the books are complete and the fault isn't yours, it counts as an incorrect filing: a 20% fine, and no fine if you file a supplementary return and pay before an audit decision (Articles 44 and 45 of Law 108/2025/QH15).
How do I know a supplier has vanished?
Look up their tax code on the tax authority portal. Status 06 means not operating at the registered address (Appendix 1 of Circular 90/2026/TT-BTC).
How long do I have to file a supplementary return?
Within 5 years from the filing deadline of the period in error, as long as it is before an inspection or audit decision (Article 12.5 of Law 108/2025/QH15).
Legal references
- Luật Quản lý thuế số 108/2025/QH15 (Điều 12, 16, 22, 44, 45)
- Nghị định 254/2026/NĐ-CP về hóa đơn điện tử, chứng từ điện tử (khoản 7 Điều 3)
- Thông tư 91/2026/TT-BTC hướng dẫn về hóa đơn điện tử (Điều 7)
- Nghị định 252/2026/NĐ-CP hướng dẫn Luật Quản lý thuế (Điều 4)
- Thông tư 90/2026/TT-BTC về đăng ký thuế (Phụ lục 1 - trạng thái mã số thuế)
- Luật Thuế GTGT số 48/2024/QH15
- Nghị định 181/2025/NĐ-CP hướng dẫn Luật Thuế GTGT, sửa đổi bởi Nghị định 144/2026/NĐ-CP
- Nghị định 320/2025/NĐ-CP hướng dẫn Luật Thuế TNDN (Điều 9)
This article is for reference and reflects regulations at the time of publishing. Every company is different, so consult an expert before applying it.
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