Yes this will work, as long as you have a DUNS number for your business, and your users have the same Apple ID country as your business is registered in (Users can change this, if they have no credit on their account and no apple subscriptions)
I believe @duskwuff is unfamiliar with the B2B program (different from the public app store and enterprise programs).
However, you will need to keep track of which codes you have given out, and you will need to register as an Apple Business (business.apple.com) with your DUNS number, to buy codes from your apple developer account. AFAIK these have to be different Apple IDs, so you're not purchasing from yourself.
Additionally, if your users download the app using a redemption code, they will not be able to see the app details page (App Store will give a generic error). However, auto-updates should work like normal, manual updates should work from the "Purchased" section of the app store, and new VPP codes/links can be redeemed as well, as a hack to update the app.