Not Operating at the Registered Address: What to Do Before Dissolution

An enterprise that has left its old head office without registering the change — commonly called “abandoning the business address” — easily falls into the legal status of “not operating at the registered address.” This status has a way out. The enterprise can either restore its tax code to keep operating, or complete tax procedures and then dissolve.

This article is for owners and legal representatives who have just discovered their company is in this status, or who want to fully close a company that has been inactive for a long time. Main conclusion: for this case, work with the tax authority first, then file the dissolution dossier.

What does “not operating at the registered address” mean?

This is a legal status recorded by the tax authority after verifying that the enterprise is not operating at its registered address. The tax authority decides on changing and ending this status, then sends the information for the business registration authority to record (Clause 3, Article 35, Decree No. 168/2025/NĐ-CP).

Under Article 16, Circular No. 90/2026/TT-BTC, this status forms in two stages:

Stage 1 — status 09, “Taxpayer pending verification of operating status at the registered address.” The tax authority moves the enterprise to this status when one of the following grounds exists, for example:

• A second notice requesting tax declaration filing has been issued, and the enterprise still has not filed.
• A letter sent by the tax authority through the post is returned because there is no recipient or the address does not exist.
• There is information together with evidence from an organization, an individual, or a document from a state agency.

At this stage, the enterprise can still file the tax declaration or explain its situation to have the status updated back.

Stage 2 — status 06, “Taxpayer not operating at the registered address.” After 05 working days without a filing or explanation, or if the explanation is not accepted, the tax authority verifies the facts on site. If the result confirms the enterprise is not operating at the address, the tax authority and the local government jointly record the minutes (Form 15/BB-XMHĐ) and issue a notice (Form 16/TB-ĐKT) within 03 working days (Clause 2, Article 16). This status is published on the Tax Administration Information System (Clause 2, Article 33).

How does this status affect the enterprise?

Knowing the consequences helps in choosing the right path and acting early.

• The tax code becomes restricted. The enterprise may only use the tax code for transactions related to deactivating or restoring the tax code (Clause 5, Article 8, Decree No. 252/2026/NĐ-CP).
• Responsibility of owners and members. If tax payment obligations are not yet complete, the owner, capital-contributing members and capital-contributing shareholders are responsible under enterprise law (Points c, e, Clause 1, Article 17, Law on Tax Administration No. 108/2025/QH15).
• Enforcement measures may apply if there is outstanding tax debt (Clause 3, Article 48, Law on Tax Administration).
• Temporary suspension of exit for the legal representative and beneficial owner, if 120 days pass from the date of the notice without the tax code being restored or deactivated (Point c, Clause 1, Article 28, Decree No. 252/2026/NĐ-CP).
• The enterprise registration certificate may be revoked. The tax authority coordinates when the business registration authority handles violations or revocation (Clause 4, Article 16, Circular No. 90/2026/TT-BTC; Point đ, Clause 1, Article 212, 2020 Law on Enterprises).

Each consequence has its own conditions. Check the tax authority’s specific notice to know which stage the enterprise is at.

Two ways out: restoring the tax code or dissolving

Steps to dissolve while in status 06

This applies to an enterprise whose tax registration follows the interlinked one-stop mechanism, covering both voluntary and compulsory dissolution (Clause 6, Article 13, Circular No. 90/2026/TT-BTC).

At step 3, the tax authority is not required to re-verify the operating status at the address (Point c, Clause 5, Article 16). So an enterprise that has already left its old head office can still proceed; the focus is completing tax and invoice obligations.

If you want to keep operating: restoring the tax code

An enterprise may request restoration once it has been notified as not operating at its address, provided its certificate has not been revoked and its tax code has not been deactivated (Point b, Clause 1, Article 17, Circular No. 90/2026/TT-BTC). The Form 25/ĐKT request must be filed before the tax authority issues the notice of tax code deactivation (Point b, Clause 4, Article 17).

Processing order (Point b, Clause 1, Article 18):

1. Within 10 working days, the tax authority notifies the obligations to be completed (Form 19.1/TB-ĐKT) and verifies at the head office; the enterprise signs the minutes.
2. The enterprise files all dossiers, pays all tax, and complies with any penalty, including obligations of dependent units.
3. Within 03 working days after that, the tax authority issues the restoration notice (Form 19/TB-ĐKT).

The tax authority will not restore the tax code if the enterprise fails to complete its obligations within 30 days from the date of notice without a valid explanation, or if verification still shows the enterprise is not operating at the head office (Point d, Clause 1, Article 18).

When the certificate has already been revoked

If the certificate is revoked at the request of the tax administration agency for tax debt enforcement, the enterprise moves to the status “Revoked due to tax administration enforcement” and does not go through dissolution procedures (Clause 4, Article 35; Clause 6, Article 69, Decree No. 168/2025/NĐ-CP). For other cases of revocation, the enterprise must go through dissolution procedures (Clause 7, Article 69). These two branches are handled differently; see the article on dissolution following certificate revocation.

What Thái Tín supports

• Checking the tax code status and legal status; reading notices and minutes to determine which stage the enterprise is at.
• Advising on which path to choose — restoration or dissolution — based on outstanding obligations and the owner’s plans.
• Drawing up a roadmap and supporting preparation of the request document and dossier within the agreed scope.
• Connecting with accounting and tax partners to file missing declarations, complete finalization and handle invoices.
• Tracking progress and reporting until the agreed scope is complete.

The tax authority and the business registration authority are the agencies that review and decide. A quote is given after the status check.

Prevention: keeping the registered address matching reality

• Register any change of head office immediately, without waiting.
• Assign someone to receive mail at the registered address, even when operations have scaled down.
• Monitor the electronic tax transaction account; the tax authority sends pending-verification information to this account and to the legal representative through electronic channels (Clause 1, Article 16, Circular No. 90/2026/TT-BTC).
• To pause for a while, use the business suspension procedure; to close for good, dissolve. See tax code status upon dissolution to read the current status correctly.

Next step: send your tax code through the contact page to have your status checked. This article is general information and does not replace advice for an individual case.

Questions and answers

Related articles

Dissolution Tax Code Status During Dissolution: How to Read It and What to Do Dissolution Dissolving a Company with Outstanding Tax Obligations Dissolution Dissolution After Revoking the Enterprise Registration Certificate