Tax code flagged as ceased or not operating at the registered address: causes and the road to restoration

On a Monday morning, a customer tells you they cannot accept your invoice because your tax code shows status 06 - not operating at the registered address. Your bank asks for documents again and a partner puts payments on hold. This is no longer a minor paperwork issue. Since 1 July 2026, Circular 90/2026/TT-BTC on tax registration has replaced Circular 86/2024/TT-BTC, and on 9 July 2026 the Ministry of Finance issued Official Letter 9409/BTC-CT requiring authorities to review and deal with companies not operating at their registered address, including revoking enterprise registration certificates, with results to be reported by 31 December 2026.

Read the tax code status correctly

The list of tax code statuses is set out in Appendix 1 to Circular 90/2026/TT-BTC. The statuses companies most often encounter are:

Why do companies end up with status 06?

Status 06 usually follows a verification in which the tax authority concludes that the company is no longer present at its registered head office. In practice, the common causes are:

• Moving office without updating the registration. For taxpayers registered directly with the tax authority, changes must be notified within 10 working days (Article 6 of Decree 252/2026/ND-CP).
• Missing tax returns for several periods, while the tax office's letters and calls go unanswered.
• Using a virtual address or virtual office: no signage, no staff on site, and the landlord does not confirm that the company operates there.
• Stopping business without any formal procedure - no suspension notice and no dissolution, leaving the company alive only on paper.

The consequences go well beyond invoices

• Restricted use of the tax code: a company notified as not operating at its registered address may use its tax code only for termination or restoration procedures (Article 8.5 of Decree 252/2026/ND-CP). During this period it also cannot file a suspension notice until the code is restored (Article 7).
• Public disclosure, including information on the owners, managers and legal representative (Article 4 of Decree 252/2026/ND-CP).
• Tax debt enforcement: a taxpayer with tax debt that is not operating at its registered address is subject to enforcement (Article 48.3 of the Law on Tax Administration No. 108/2025/QH15).
• Exit restrictions: the legal representative or beneficial owner of a company no longer operating at its registered address, with unpaid tax, must settle the tax before leaving Vietnam (Article 17.5(b) of Law 108/2025/QH15).
• Personal liability: the owner of a single-member limited liability company, general partners and the owner of a private enterprise are responsible for settling the tax obligations of a company not operating at its registered address (Article 17.1 of Law 108/2025/QH15).
• Revocation of the enterprise registration certificate under Article 69 of Decree 168/2025/ND-CP, particularly for long-standing tax debt and non-cooperation, which Official Letter 9409/BTC-CT asks authorities to resolve.

The road to restoring the tax code

Under Article 17 of Circular 90/2026/TT-BTC, a company notified as not operating at its registered address may apply to restore its tax code if its enterprise registration certificate has not been revoked and its tax code has not been terminated. In practice, the path looks like this:

1. Assess the current position: legal status on the enterprise registration system, missing tax returns, tax debt, late payment interest, penalties and the status of invoice use.
2. Fix the address: if the company moved without updating its records, prepare a written explanation and a change-of-registration file in parallel with the restoration request.
3. Submit a restoration request on Form 25/DKT to the tax office directly managing the company, signed by the legal representative or an authorized person.
4. Clear outstanding obligations: file all missing returns and pay all tax, late payment interest and penalties before restoration (Article 7.1(dd) of Decree 252/2026/ND-CP), subject to the exceptions set out in the decree.
5. On-site verification by the tax office, which records its findings in minutes. Make sure staff, records and signage are present at the address when the officers arrive.
6. Receive the Notice of Tax Code Restoration (Form 19/TB-DKT). The information is passed to the enterprise registration system. Then re-check the status on the lookup portal and inform customers and banks.

Prevention: three simple habits

• Update registration details immediately when the head office, legal representative, phone number or email for tax notices changes.
• Keep filing tax returns on time, including periods with no revenue.
• Check your own tax code status regularly, especially after relocating or changing accounting service providers.

How Kaizen can help

Kaizen supports companies from reviewing outstanding obligations and preparing the restoration file to working with the tax office during address verification, until the tax code is back to normal. If you want to know your weak points before the tax authority comes to verify, book a free tax health check with our team of advisors with more than 17 years of Big4 experience.