1. The Current Status of Vietnam’s Administrative Boundaries from July 1, 2025:

Vietnam officially adopts a two-tier local government model, consisting of: (i) provinces and centrally governed cities, and (ii) commune-level administrative units, in accordance with Article 110 of the Constitution (as amended in 2025) and Resolution No. 202/2025/QH15 of the National Assembly, effective from July 1, 2025.

According to Resolution No. 202/2025/QH15, after the restructuring, Vietnam has 34 provincial-level administrative units, including 28 provinces and 06 cities. Among them, 19 provinces and 04 cities were formed after the restructuring, and 11 provinces and cities were not restructured: Cao Bằng, Điện Biên, Hà Tĩnh, Lai Châu, Lạng Sơn, Nghệ An, Quảng Ninh, Thanh Hóa, Sơn La, and the cities of Hà Nội and Huế.

Accordingly, the entire natural area and population size of Ho Chi Minh City, Bà Rịa – Vũng Tàu Province, and Bình Dương Province were merged into a new city – Ho Chi Minh City. After the restructuring, Ho Chi Minh City has a natural area of 6,772.59 km² and a population of 14,002,598 people. Thus, Ho Chi Minh City will border Đồng Nai, Đồng Tháp, Lâm Đồng, Tây Ninh provinces and the East Sea.

At the same time, Ho Chi Minh City is organized into 168 commune-level administrative units, including 113 wards, 54 communes, and 01 special zone; among them, 112 wards, 50 communes, and 01 special zone were formed after the restructuring, and 05 commune-level administrative units were not restructured: Thới Hòa Ward, Long Sơn, Hòa Hiệp, Bình Châu, and Thạnh An Communes.

Thus, the restructuring of administrative boundaries throughout Vietnam in general and Ho Chi Minh City in particular has been implemented comprehensively and consistently. This will lead to significant impacts on business operations and tax declaration and accounting for enterprises.

2. Change of Address on Business or Investment Licenses:

Before the restructuring, on April 5, 2025, the Ministry of Finance issued Official Letter No. 4370/BTC-DNTN guiding business registration in case of changes in administrative boundaries. Accordingly, enterprises, household businesses, cooperatives, unions of cooperatives, and cooperative groups are allowed to continue using their issued Enterprise Registration Certificates, Household Business Registration Certificates, Cooperative Registration Certificates, Cooperative Group Registration Certificates, Branch/Representative Office/Business Location Registration Certificates (hereinafter collectively referred to as “Certificates”).

Therefore, the business registration authority is not allowed to require enterprises to immediately register for changes of address according to the new administrative boundaries. Accordingly, enterprises may choose to update their information when needed or concurrently with other changes.

3. Change of Tax Registration Information:

In line with the administrative boundary restructuring, Vietnam now has 34 provincial or city-level Tax Departments (new names of tax authorities) in 34 provinces and cities, each headed by a Chief Tax Officer. Each Provincial or City Tax Department is further divided into local Tax Sub-Departments, with a total of 350 nationwide. Specifically, Ho Chi Minh City Tax Department is organized into 29 local Tax Sub-Departments.

Previously, on June 27, 2025, the District Tax Sub-Department II (which was in charge of Ho Chi Minh City before the restructuring) issued Notice No. 11984/TB-CCTKV02 to guide the change of taxpayer address according to the new administrative boundaries. Accordingly, the tax authority does not require taxpayers to adjust their address information on the Certificate.

At the same time, the taxpayer’s address on the invoice may reflect the address updated by the tax authority according to the new administrative boundary list, while still retaining the old address on the Certificate. Updating the address information on the Certificate is optional, as analyzed in Section 2 above.

However, it should be noted that the aforementioned Notice was issued by District Tax Sub-Department II, which has now been reorganized and renamed as Ho Chi Minh City Tax Department. Therefore, this Notice is only applicable in the pre-restructuring area of Ho Chi Minh City. In the near future, the General Department of Taxation and/or provincial and city Tax Departments should issue official documents to provide a consistent legal basis for enterprises to apply nationwide.

4. Some Issues to Note:

As previously analyzed, current laws do not require enterprises to immediately update their address according to the new administrative boundaries on their Certificates and tax information. However, enterprises may face some difficulties related to the change, such as:

(a) To ensure clarity in transactions and smooth customs clearance, enterprises must ensure that the address information on commercial and customs documents such as: Bills of Lading, Commercial Invoices, Import-Export Contracts… is accurate and matches the Certificate. In case of discrepancies, enterprises may face risks during explanation with state authorities, and transactions or import-export procedures may be delayed.

(b) In certain specialized sectors such as pharmaceuticals, drug packaging, functional foods…, when applying for licenses or product announcements, regulatory authorities often require that the enterprise’s address match the information registered on the Certificate.

(c) During inspection or audit activities by state authorities, using inconsistent address information may result in explanation requests, delay in dossier processing, or directly affect the enterprise’s legal rights.

5. Implementation Recommendations:

Based on the current guiding documents, enterprises are not yet required to immediately update their address according to the new administrative boundaries. However, to ensure consistency of information and minimize legal and transactional risks, enterprises should proactively carry out procedures to update their address information on the Certificate and tax records in accordance with the new administrative divisions.

Synchronizing address information helps ensure consistency between invoices, contracts, and certificates; enhances transparency and professionalism in transactions with partners; reduces the risk of misunderstandings, transaction refusals, or legal issues due to inconsistent information. Additionally, it facilitates tax declaration, settlement, and administrative procedures with government agencies.

In the context of Vietnam’s administrative and tax systems gradually being streamlined and digitized, updating enterprise information in a timely and synchronized manner is not only relatively quick to execute but also ensures compliance and contributes to the enterprise’s long-term sustainable development.