🚨 ARE ENTERPRISES EXPOSED TO POTENTIAL RISKS FROM MANAGING MULTIPLE ACCOUNTING DATA SYSTEMS?
📖 Legal basis and reference sources
• Official letter No.2335/TCS13-NVDTPC dated 8 June 2026, issued by Local Tax Authority No. 13 of Thanh Hoa Province,
regarding measures to enhance compliance with accounting and tax laws and prevent the maintenance of maintaining
two or more sets of financial accounting books for the purpose of concealing revenue or evading tax.
• Notice No.394/TB-CT dated 29 May 2026, issued by the Tax Department.
• Clause 4, Article 45 of the 2025 Law on Tax Administration and the relevant accounting and tax regulations
referred to in the Official Letter.
Many enterprises use accounting software, point-of-sale (POS) software, ERP, CRM, and internal management reports concurrently.
This is a normal business management requirement and does not, in itself, constitute a violation of the law.
However, under the applicable accounting and tax regulations, enterprises must ensure that their accounting data is recorded
truthfully, completely, and consistently and can be reconciled and explained in the event of an inspection by the competent authorities.
🔎 Warning signs that businesses should proactively review
⚠️ Revenue recorded in the sales system does not reconcile with electronic invoices or tax filings.
⚠️ Data in the accounting records, financial statements, and internal management systems is inconsistent.
⚠️ Actual cash flows contain discrepancies for which no supporting basis or reasonable explanation is available.
⚠️ Revenue has arisen but has not been fully recorded in accordance with the applicable regulations.
⚠️ Multiple software systems are used without an established mechanism for data reconciliation and control.
⚠️ Invoices or supporting documents are used in a manner inconsistent with the applicable regulations, or transactions are recorded inconsistently with their actual substance.
📌 Is an internal management report considered a “second set of accounting books”?
NO.
Enterprises may still use:
✅ Management accounting report;
✅ Internal analysis report;
✅ Reports prepared for parent companies or investors;
✅ Reporting prepared in accordance with international standards;
✅ ERP, POS, BI, and other business management systems.
However, such data must:
✔ Be reconcilable with the accounting books and supporting documents;
✔ Be supported by a reasonable and verifiable basis for explanation;
✔ Not be used to conceal revenue, assets, liabilities, receivables, payables, or tax obligations.
❌ Certain Acts Prohibited by Law
• Maintaining two or more sets of financial accounting books containing different figures for
the same accounting period.
• Omitting revenue, assets, or liabilities from the accounting books contrary to the applicable regulations.
• Forging, making false declarations in, or erasing and altering accounting documents.
• Recording revenue or expenses inconsistently with the substance of the transactions for the
purpose of misstating tax liabilities.
⚖️ Potential Legal Risks
Where a violation occurs, depending on its nature and severity, the organization or individual concerned may:
🔸 Be subject to administrative penalties for violations of accounting and tax regulations;
🔸 Be subject to retrospective tax assessment, late payment interest, and other financial obligations
in accordance with the applicable regulations;
🔸 Be subject to criminal liability in accordance with the law where the conduct constitutes a criminal offence.
✅ What should enterprises do?
✔ Regularly reconcile data among the accounting records, electronic invoices, and payment records.
✔ Establish internal control procedures and clearly define responsibilities.
✔ Use software systems capable of data integration and synchronization.
✔ Maintain complete records of contracts, invoices, and supporting documents.
✔ Proactively review and rectify any errors in accordance with the applicable regulations
before an inspection or examination is conducted by the competent authorities.
💡 Key Message
Enterprises may use multiple software systems and various types of reports for management purposes.
What matters is that all data must be consistent, reconcilable, capable of being explained,
and accurately reflect the substance of the underlying transactions.
📌 This article is provided for general legal information purposes only and does not constitute
or replace legal or tax advice for any specific case.
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