One person books through an online travel agency (OTA), someone else comes to stay, and at check-out somebody asks for an invoice. The short answer:
📌 Decree 254/2026/ND-CP has no specific provision for a booker who is not the guest; the safe reading is that the invoice follows the buyer who provides the information:
- A company: name, address and tax code exactly as on its business or tax registration certificate (Appendix, section 4(a)).
- An individual: name, address and personal identification number when the guest provides them; for a foreign guest these can be replaced by the passport or entry–exit document number and nationality (Appendix, section 4(b)).
- Nobody provides details: the invoice clearly states it is sold to a consumer, and such an invoice cannot be used by a business to record expenses (Appendix, section 4(b)).
In a specific case, the hotel should ask the tax authority that directly manages it.
This article is written from the point of view of front desk and accounting staff at mini hotels, guesthouses and homestays: which rules apply now, two common cases where the booker is not the guest, how to read the buyer section of the Decree's Appendix, whose name goes on the invoice for an OTA booking (what is clear and what to ask the tax authority), when to issue the invoice, and a five-step front desk routine so the invoice is right the first time.
The article is not tax advice and does not replace the tax authority's view. Quotations are unofficial translations of the Vietnamese text and always carry the article, clause or Appendix section, so the hotel can check the original.
Part 1: Which rules apply to room invoices
From 1 July 2026, e-invoices follow Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC. Decree 123/2020/ND-CP and Decree 70/2025/ND-CP ceased to be effective on 1 July 2026 (Decree 254, Article 43); Circular 32/2025/TT-BTC also ceased to be effective on 1 July 2026 (Circular 91, Article 25).
When you look up an invoice question, check which document the answer cites: many older guides still cite rules from before July 2026.
📚 How to read this article. Quotations from the documents are in quotation marks and always carry the article, clause or Appendix section. A sentence that starts with “the Decree has no specific provision…” is the writer's safe reading and always comes with the advice to ask the tax authority. Items under “Questions this article does not answer” are open questions that the article deliberately leaves open.
Part 2: When the booker is not the guest — two common front desk cases
In a small hotel, a booker who is not the guest is perfectly normal. What differs is who needs the invoice and what it will be used for. Here are two cases the front desk sees often, with the questions to ask.
Case 1: A company books for an employee on a business trip
The admin team books online or by email, the employee stays, and at the end of the trip the employee needs an invoice in the company's name to hand in to accounting. The invoice user here is the company, so the details needed are the company's. For a business buyer, the Appendix to Decree 254, section 4(a): “the buyer's name, address and tax code shown on the invoice shall follow the business registration certificate, branch registration certificate, household business registration certificate, tax registration certificate or tax code notice…”.
The safe way at the desk: ask the company to send its invoice details in writing, for example an email or a message with a photo of its registration certificate, rather than copying from a business card or taking them over the phone. The name on a card is often a short trading name that can differ from the registered name. Ask for five things:
- The company's full name, exactly as on its registration certificate.
- The address on the registration, not the office address if the two differ.
- The tax code, received in writing, not read out.
- The email of the company's accounting team for the invoice.
- Which charges the company pays: room only, or breakfast, laundry and drinks as well.
The last question is often forgotten: many companies pay only for the room, while minibar and laundry are paid by the employee.
Case 2: Family, friends or partners book on someone's behalf, including for foreign guests
A son books for his parents, a friend books for the whole group, a partner abroad books for a foreign guest. The payer is one person, the guest another, and usually nobody needs the invoice for accounting. When someone asks for an invoice, the desk should ask two things: what the invoice is for, and whose details it should carry. Personal details, or the passport number and nationality for a foreign guest, follow Appendix section 4(b) (see the table in Part 3) and are read back to the guest.
When two people both want the invoice in their own name, or a foreign guest needs an invoice in the name of their company, the desk notes the request and passes it to accounting before the invoice is issued.
What the two cases have in common
Decree 254 has no specific provision for a payer who is not the guest; the safe reading is that each invoice carries the details of the buyer of the part of the service that person pays for: a company paying for the room needs an invoice with the company's name and tax code, while a guest paying for the minibar or laundry receives a separate invoice. In a specific case, the hotel should ask the tax authority that directly manages it.
For the front desk, the question to ask is who pays for what, and who needs an invoice for it; the booker is only the contact.
Part 3: Reading the buyer section of the Appendix correctly
Section 4 of the Appendix to Decree 254 sets out buyer information by type of buyer. The table puts each rule next to what the front desk should do:
| Buyer | Appendix, section 4 | At the desk |
|---|---|---|
| Business | Name, address and tax code exactly as on the business or tax registration certificate (point a) | Get the details in writing and check them against a photo of the certificate |
| Individual who provides name, address, ID number | The invoice shows these details (point b) | Ask whether the guest wants the details on the invoice; if so, read them back |
| Foreign guest | May be replaced by passport or entry–exit document number and nationality (point b) | Copy the passport number and nationality from the document shown |
| Buyer gives no details | The invoice clearly states it is sold to a consumer (point b) | Tell the guest beforehand: a business cannot use this invoice to record expenses |
This is why business travellers often come back to the desk asking for the invoice to be reissued. The low-effort fix: ask for the company details at check-in, while the guest still has time to message the office.
The guest has left: who signs the invoice?
An e-invoice does not need the buyer's digital signature unless the buyer and the seller have agreed otherwise (Decree 254, Article 10(1)(e)); just send it to the accounting email the company provided and keep the sent email.
Part 4: Whose name goes on the invoice for an OTA booking
A booking through an online travel agency (OTA) adds a third party, and this is where much of the advice online goes further than the documents. Under Decree 254, two points are clear; the rest are questions for the tax authority.
The first clear point: the hotel is the seller of the accommodation service
The hotel provides the accommodation service to the guest. Decree 254, Article 4(1): “When selling goods or providing services, the seller shall issue an e-invoice to deliver to the buyer…”. So for a small hotel, keeping complete information for every booking is the hotel's own job.
The next clear point: when the invoice is issued
Decree 254, Article 9(2), first sentence: “The time of issuing an invoice for the provision of services is the time the provision of the service is completed (including services provided to foreign organisations and individuals), regardless of whether payment has been received.” Second sentence: “Where the service provider collects money before or during the provision of the service, the time of issuing the invoice is the time the money is collected (excluding deposits collected under the Civil Code to secure performance of the service contract).”
For channel bookings, record three facts on each booking: whether the guest prepaid or will pay at the hotel; who collected that money; and whether it is room money or a deposit. With these three facts, accounting can check the booking against Article 9(2) and put a specific question to the tax authority.
Questions this article does not answer
❓ Open questions, deliberately left unanswered:
- When the online travel agency (OTA) collects payment from the guest, who is the “buyer” on the room invoice: the guest, the booker, or another party?
- Is money the guest prepays at booking a deposit under the Civil Code, or money collected in advance for the service?
- How is the commission the hotel pays the online travel agency documented and declared?
- Does your hotel fall under the group that uses e-invoices generated from cash registers?
Each depends on the contract between the hotel and the channel, how the money moves and the documents for each booking. In a specific case, the hotel should ask the tax authority that directly manages it.
When you ask, attach the channel contract, a sample booking with the guest's personal details masked and a description of how the money moves; keep the written answer with the accounting records.
Part 5: When to issue the room invoice — after the stay, prepaid, deposit
Three familiar payment situations at a small hotel, next to the relevant sentence of Decree 254, Article 9(2):
| At the desk | Relevant sentence of Article 9(2) |
|---|---|
| The guest pays after the stay | The invoice is issued when the service is completed, whether or not payment has been received |
| The guest pays in advance, or during the stay | The invoice is issued when the money is collected |
| The guest sends a deposit to hold the room | Money established to be a deposit under the Civil Code securing performance of the contract is not a case for issuing an invoice at the time it is collected |
The third row only applies when the money really is a deposit. Whether money sent in advance is a deposit or an advance payment for the service depends on the specific contract and documents, not on what the receipt calls it; it is one of the open questions in Part 4 (see the note on the tax authority there).
What the desk can do now: record clearly on the receipt and in the software whether the money is prepaid room money or a deposit, matching what the guest was told when the room was held.
Part 6: A five-step front desk routine — ask at the right time, record in the right place
Many invoice problems at small hotels come from information arriving late: the guest has gone home and then asks for a company invoice. These five steps get the information in on time.
Step 1: When taking the booking
Ask whether the guest needs an invoice; for company guests, ask for the invoice details in writing. For channel bookings, note on the booking whether the guest prepaid or will pay at the hotel.
Step 2: At check-in — ask one question
One question is enough: “Will you need an invoice, and should it carry company or personal details?” If it is a company, ask which charges the company pays. If the guest does not have the company details yet, remind them to send them before check-out.
Step 3: During the stay — post services to the right bill
Minibar, laundry and drinks are posted as they happen, to the right bill: the room bill if the company pays, the services bill if the guest pays. Leaving it all until check-out to split is slow and things get missed.
Step 4: At check-out — read back before issuing
Show the guest the statement for each bill. Company invoice: check name, address and tax code against what the company sent in writing. Personal invoice: read back the name and document number. No details provided: say clearly that the invoice will be marked as sold to a consumer.
Step 5: After check-out — send and file
Send the invoice to the guest's email or to the company accounting email provided, then file with the booking: the written invoice details, the statement and the email that delivered the invoice.
🗂️ Four lines for the front desk: “Will you need an invoice?” · “Company or personal details?” · “Which charges does the company pay?” · “Could you send the company details by email or message?”
Part 7: If the hotel is a household business
Many mini hotels, guesthouses and homestays are registered as household businesses. Decree 254, Article 6(1)(d): a household business with annual revenue above VND 1 billion falls under the group that uses e-invoices with a tax authority code, or e-invoices generated from cash registers with a data connection to the tax authority. Which one to use is an open question from Part 4, for the tax authority that manages the business.
Part 8: Where DiCloud helps with invoices
DiCloud is hotel management software; it does not replace accountants or the tax authority. For room invoices, DiCloud does three things:
- Split payment: room charges on one bill, services such as the minibar on another, so separate invoices can be issued to the company and to the guest. This fits the case where the company pays for the room and the employee pays for services.
- Connection with the e-invoice provider the hotel already uses. DiCloud does not issue e-invoices itself; the hotel keeps its own e-invoice provider.
- The in-house guest's details are pulled in for the invoice, with no retyping. Useful when the guest provides a name, ID number, or passport number and nationality for the invoice.
The guest's details are in the software from check-in; how to capture them without retyping is covered in the article on guest registration without retyping. For the books after the invoice is issued, see small hotel accounting under Circular 99 and DiHotel's page on the DiACC accounting module.
What DiCloud does not decide for the hotel: whose details go on the invoice, whether a prepayment is a deposit or an advance payment, and tax questions. Those belong to the hotel's accountant and the tax authority.
Want to see how room and service bills are split in DiCloud?
Tell the DiCloud team which e-invoice provider the hotel uses and which invoice situations come up at the desk. We will check whether DiCloud is connected with that provider and show you how to split bills for business travellers.
Ask the DiCloud team for freeFrequently asked questions
Whose name goes on the invoice when the booker is not the guest?
Decree 254/2026/ND-CP has no specific provision for this case; the safe reading is that the invoice follows the buyer who provides the information for it. For a company, the name, address and tax code as shown on its registration certificate (Appendix, section 4(a)); for an individual, the name, address and personal identification number when the guest provides them (Appendix, section 4(b)). In a specific case, the hotel should ask the tax authority that directly manages it.
What goes on the invoice if the guest gives no details?
Under the Appendix to Decree 254/2026/ND-CP, section 4(b), when the buyer does not provide a name, address or personal identification number, the invoice clearly states that it is sold to a consumer. Such an invoice cannot be used by a business to record expenses, so a guest on a business trip who needs a company invoice needs to give the company details before the invoice is issued.
What details are used for a foreign guest?
Under the Appendix to Decree 254/2026/ND-CP, section 4(b), for a foreign buyer who provides information for the invoice, the address and personal identification number may be replaced by the passport or entry–exit document number and the guest's nationality. The front desk should copy them exactly from the document shown and read them back to the guest.
For an OTA booking, what is clear under Decree 254?
Two points are clear. The hotel provides the accommodation service, and Decree 254/2026/ND-CP, Article 4(1) states that when providing a service, the seller issues an e-invoice to deliver to the buyer. The time of issuing the invoice follows Article 9(2). Who the buyer on the invoice is when the online travel agency (OTA) collects payment from the guest is an open question this article does not answer; it is one to put to the tax authority.
When is the room invoice issued?
Under Decree 254/2026/ND-CP, Article 9(2), for services the invoice is issued when the provision of the service is completed, whether or not payment has been received. If payment is collected before or during the service, the invoice is issued when the money is collected, except for a deposit under the Civil Code securing performance of the contract.
Does DiCloud issue e-invoices itself?
No. DiCloud connects with the e-invoice provider the hotel already uses. DiCloud can split payment, with room charges on one bill and services such as the minibar on another, so separate invoices can be issued to the company and to the guest, and it pulls in the details of the in-house guest for the invoice, with no retyping.
Conclusion
When the booker is not the guest, the question of whose name goes on the invoice is easier if you ask it differently: who pays for what, and who provides the details for the invoice. What is clear sits in Appendix section 4 and Article 9(2) of Decree 254/2026/ND-CP. What is not, especially when an online channel collects payment on the hotel's behalf, is a question for the tax authority. In a specific case, the hotel should ask the tax authority that directly manages it.
DiCloud is part of the DiHotel Solutions Corps ecosystem, a company with more than 20 years of developing hotel software, serving more than 300 accommodation properties in Vietnam and Japan. As cloud AI hotel management software for mini hotels, guesthouses, homestays and 1–3 star hotels, and as online AI hotel management software, DiCloud opens on the front desk computer as well as on a phone.
For 4–5 star hotels, resorts and multi-property chains, DiHotel, the AI hotel management software, is the original platform. The companion article on the DiHotel Blog takes on group check-outs: group check-out: splitting the company and guest bills