Maintaining two parallel accounting systems may result in penalties for tax evasion

Maintaining two parallel accounting systems may result in penalties for tax evasion

On June 10, 2026, the Dong Thap Provincial Tax Department issued công văn (official letter) No. 663/TCS5-NVDTPC regarding the dissemination of information to improve compliance with accounting and tax laws and to prevent the practice of maintaining two or more financial accounting systems.

According to recommendations from the Tax Department of Dong Thap province, the act of “not recording or documenting in accounting books the revenue related to determining the amount of tax payable” is considered tax evasion under the Law on Tax Administration. Furthermore, the law also lists the act of “establishing two or more financial accounting systems or providing or publishing financial reports with inconsistent data within the same accounting period” as prohibited acts.

In cases where a business uses both a financial accounting system and a management accounting system, internal reports, budgets, ERP/POS/BI systems for business management or parent company reports, reports according to international standards, etc., will be considered legal if the business can verify and explain this data to the tax authorities and absolutely not use it to conceal transactions, revenue, assets, or tax obligations.

Besides the practice of maintaining two sets of financial accounting books simultaneously, tax authorities will also strengthen supervision and inspection of businesses with the following signs of tax and accounting risks:

  • Significant discrepancies between actual revenue generated, figures on issued invoices, and cash transactions through banks or cash;
  • Inconsistent accounting data between internal accounting books and tax returns and financial reports submitted to the tax authorities;
  • Aand the parallel use of multiple sales management or accounting software programs that lack the ability to connect, synchronize data, or have the function to track data modifications, creating opportunities for concealing information.

To avoid penalties and tax arrears, businesses need to immediately take the following steps:

  • (i) review their entire accounting system, books, documents, and financial reports to promptly correct any errors before tax authorities conduct inspections and audits;
  • (ii) apply the correct accounting system for their type of business;
  • (iii) choose and use accounting software, sales management software, and electronic invoicing solutions that can synchronize data, track edits, and have mechanisms to warn of unusual activity. Absolutely do not use software features to conceal tax obligations or create two accounting systems;
  • (iv) Limit cash transactions to facilitate verification and inspection by tax authorities.
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