Relocating a head office is common when a company expands, optimises premises costs or restructures. But it is not just “moving offices” — the law imposes a mandatory sequence with tight deadlines. This article sets out 6 key notes under the framework in force as of 14/10/2026.
1. Distinguish the two cases: same vs. different tax administration authority
This is the most important classification, determining the entire sequence. Under Clause 1, Article 40 of Decree 168/2025/ND-CP, where a head-office relocation results in a change of the directly managing tax authority (typically an inter-provincial move), the enterprise must complete the tax procedure for the relocation under tax law BEFORE registering the change with the business registration authority — the “tax first, business registration second” principle. Specifically: file the adjusted/supplementary tax registration declaration (form 08-MST) with the current directly managing tax authority (the place of departure) under Circular 90/2026/TT-BTC, obtain the notice of taxpayer relocation (form 09-MST), and only then file the change registration dossier. Conversely, if the move stays under the same tax authority (typically within one province/city), the enterprise files the Article 40(2) dossier directly with the provincial business registration authority of the new head-office location. Exception: address changes resulting from administrative boundary changes under a competent state authority’s decision do not follow the relocation procedure above.
2. Prepare the correct resolution/decision for your company type
The change dossier (Article 40(2)) comprises: (a) the application for enterprise registration change; (b) a copy or original of the resolution/decision on the head-office relocation adopted by the company owner (single-member LLC), the Members’ Council (multi-member LLC, partnership) or the General Meeting of Shareholders (joint-stock company). Using the wrong issuing body (e.g., only a Director’s decision where a Members’ Council resolution is required) gets the dossier returned. The date of the resolution/decision is the starting point for the 10-day deadline below — keep this document safe.
3. Meet the 10-day change registration deadline
Under Clause 2, Article 30 of the Enterprise Law 59/2020/QH14 (as amended by Law 76/2025/QH15), an enterprise must register changes to its Enterprise Registration Certificate within 10 days from the date of the change — the head-office address being one of the contents listed in Article 28. Note: the tax step comes first, so these 10 days must accommodate the tax relocation procedure — do not wait until the deadline is near to start the tax step. (Distinguish: Article 31 of the Enterprise Law governs “notification of enterprise registration changes” — a different procedure, not the basis of this 10-day deadline.)
4. Track the inter-agency coordination between business registration and tax
Under Clause 3, Article 40 of Decree 168/2025/ND-CP, after receiving the dossier, the business registration authority forwards the relocation information to the tax authority; the tax authority responds within 01 working day; the business registration authority then issues the new Enterprise Registration Certificate within 03 working days (for a valid dossier). Enterprises should proactively track progress at both ends, as delays in coordination can push issuance beyond expectations. Note: Decree 296/2026/ND-CP (effective 23/7/2026) does not amend Article 40 of Decree 168/2025 — the sequence above stands; for online filings, comply with the digital-identity account and electronically authenticated authorisation rules under amended Article 39.
5. Publish the change on the National Portal within 30 days
Under Article 32 of the Enterprise Law, when enterprise registration contents change, the enterprise must publicly announce the change on the National Enterprise Registration Portal within 30 days (check the original text of Clauses 2 and 3 of Article 32 for the exact starting point). This is an obligation independent of receiving the new certificate — many enterprises “forget” this step after collecting it. Sanctions apply to failure to publish or late publication, so add this to the checklist and keep proof of completion.
6. Review the “post-move” items: what must be updated to the new address
Under Clause 4, Article 40 of Decree 168/2025, changing the head-office address does not change the enterprise’s rights and obligations — but in practice the enterprise must update the new address across documents and systems: e-invoices (updating e-invoice usage information under Decree 254/2026/ND-CP), digital signatures, bank accounts, ongoing contracts, sub-licences and office signage; and notify partners and customers. Missing this can lead to invalid invoices, stuck banking transactions or disputes over notice addresses in contracts. Special note on the 2025 administrative boundary changes: where the address changes purely due to boundary changes, there is no obligation to replace the Enterprise Registration Certificate — the tax authority determines the taxpayer’s address based on the still-valid certificate.
Frequently asked questions
What is the difference between an inter-provincial move and a move within one province?
The tax step. An inter-provincial move usually changes the directly managing tax authority → the tax relocation procedure must come first (form 08-MST, receive form 09-MST), then the change registration (“tax first, business registration second” — Article 40(1), Decree 168/2025). A same-province move (same tax authority) files the change dossier directly.
When does the 10-day period start?
From the date of the change — in practice, the date of the resolution/decision on the head-office relocation by the owner/Members’ Council/General Meeting of Shareholders (Article 30(2), Enterprise Law).
Can I skip the tax procedure and register the change directly?
No, if the move changes the directly managing tax authority. Article 40(1) of Decree 168/2025 requires completing the tax procedure before registering the change.
Where and within how long must the change be published?
Publicly on the National Enterprise Registration Portal, within 30 days under Article 32 of the Enterprise Law (check Clauses 2 and 3 of the original text for the exact starting point).
Must I do anything if the address changes due to an administrative merger?
The tax relocation procedure for ordinary moves does not apply, and there is no obligation to replace the Enterprise Registration Certificate merely because boundaries changed.
What if I forget to update the new address on e-invoices?
Invoice address information must match the registration; updates follow Decree 254/2026/ND-CP. Put this on the checklist as soon as the new Enterprise Registration Certificate is issued.
Sources
- Enterprise Law 59/2020/QH14 (amended by Law 76/2025/QH15) — in force as of 14/10/2026: Article 30(2) (10-day change registration deadline), Article 32 (publication of enterprise registration information, 30-day period);
- Decree 168/2025/ND-CP (amended by Decree 296/2026/ND-CP, which does not amend Article 40) — effective 01/7/2025: Article 40 (head-office relocation procedure; “tax first, business registration second” principle; 01-working-day inter-agency coordination + new certificate within 03 working days; enterprise rights and obligations unchanged);
- Circular 90/2026/TT-BTC — effective 01/7/2026: tax relocation procedure (forms 08-MST, 09-MST);
- Decree 254/2026/ND-CP — current e-invoicing framework (replacing Decree 123/2020/ND-CP since 01/7/2026), applicable to updating e-invoice usage information;
- Law on Tax Administration 108/2025/QH15, Decree 252/2026/ND-CP — current tax administration framework (effective 01/7/2026).
For reference only; not legal advice. This article was drafted by AI and quality-checked by the AI Legal Council of FLAT Law Firm; it has not been reviewed or approved by a human lawyer. Regulations may change; please check the current legal texts before applying.
Related articles
- Changing a Company Registered Office Address in Vietnam
- Enterprise Registration Changes in Vietnam: Procedures and Dossiers
Preparing to relocate your head office and need a review of the tax — business registration sequence? Contact FLAT Law Firm for advice.
