Update on e-Invoice Implementation
Is a Special Purpose Vehicle (SPV) under Section 60I of the Income Tax Act 1967 required to implement e-Invoice?
Yes, an SPV under Section 60I is required to implement e-Invoice and must obtain its own tax identification number (TIN) to fulfill its e-Invoice obligations.
(extracted from LHDN website e-invoices General FAQs, Q8, refer https://www.hasil.gov.my/media/0xqitc2t/lhdnm-e-invoice-general-faqs.pdf)
If a business commences operations in 2023 or later, when is the e-Invoice implementation date for the said business?
A business with non-individual shareholder(s) (or equivalent), or one that is a subsidiary of a holding company, has related companies, or operates under a joint venture with an annual turnover or revenue exceeding RM150,000, is required to implement e-Invoice starting from 1 July 2025 or upon its commencement of operations, whichever is later.
Meanwhile, a business without non-individual shareholder(s) (or equivalent), that is not a subsidiary of a holding company, and does not have related companies or joint ventures, must implement e-Invoice starting from 1 July 2025 or upon its commencement of operations—except when its annual turnover or revenue is below RM150,000.
For more details, please refer to Part 3: e-Invoice for MSMEs in LHDN e-invoices General FAQs.
(extracted from LHDN website e-invoices General FAQs, Q11, refer https://www.hasil.gov.my/media/0xqitc2t/lhdnm-e-invoice-general-faqs.pdf)
For certain corporate agents where the existing process includes the issuance of invoices to companies, can the current process of the corporate agent issuing the e-Invoice be maintained instead of using self-billed e-Invoice?
The buyer (i.e., the taxpayer making payments to agents, dealers, and distributors) is required to issue a self-billed e-Invoice for payments or incentives (whether in monetary form or otherwise) made to agents, dealers, and distributors, as outlined in Section 9.4 of the e-Invoice Specific Guideline.
This requirement applies regardless of whether the agents, dealers, and distributors are individuals or corporations (i.e., suppliers in this case). The buyer must share the validated self-billed e-Invoice with the supplier upon validation. Accordingly, agents, dealers, and distributors are not required to issue an e-Invoice to the taxpayers who make payments.
(extracted from LHDN website e-invoices General FAQs, Q55, refer https://www.hasil.gov.my/media/0xqitc2t/lhdnm-e-invoice-general-faqs.pdf)
Are Malaysian buyers required to include the import duty and/or sales tax levied by RMCD upon customs clearance on imported goods when issuing a self-billed e-Invoice?
No, Malaysian buyers are not required to include duties and/or taxes levied by the Royal Malaysian Customs Department (RMCD) in the self-billed e-Invoice.
(extracted from LHDN website e-invoices General FAQs ,Q66, refer https://www.hasil.gov.my/media/0xqitc2t/lhdnm-e-invoice-general-faqs.pdf)
Update – List of International Organizations Exempted from Implementing e-Invoice
The updated list of international organizations engaged in the transaction of any goods sold or services performed before 1 July 2025 is exempt from implementing e-Invoice.
(Refer to LHDN website e-invoices Guideline, Appendix 3, https://www.hasil.gov.my/media/fzagbaj2/irbm-e-invoice-guideline.pdf)
Additional Situations Where Buyers Require Issue Self-Billed e-Invoices
When a sale or transaction is concluded, an e-Invoice is issued by the Supplier to recognize the Supplier's income (proof of income) and serve as a record of purchases made or expenses incurred by the Buyer (proof of expense).
However, in certain circumstances, another party (other than the Supplier) is required to issue a self-billed e-Invoice. For e-Invoice purposes, the Buyer must issue self-billed e-Invoices for the following transactions:
Currently Situations for Self-Billed e-Invoicing:
- Payments to agents, dealers, distributors, etc. (Refer to Section 9 of the e-Invoice Specific Guideline)
- Goods sold or services rendered by foreign suppliers (Refer to Section 10.4 of the e-Invoice Specific Guideline)
- Profit distribution (e.g., dividend distribution) (Refer to Section 11 of the e-Invoice Specific Guideline)
- Electronic commerce (e-commerce) transactions (Refer to Section 14 of the e-Invoice Specific Guideline)
- Payouts to all betting and gaming winners
- Transactions with individuals who are not conducting a business (Applicable only if other self-billed circumstances do not apply)
- Interest payments, except:
- Businesses (e.g., financial institutions) that charge interest to the public at large (regardless of whether the recipients are businesses or individuals)
- Interest payments made by an employee to an employer
- Interest payments made by a foreign payor to Malaysian taxpayers
- Claims, compensation, or benefit payments from the insurance business of an insurer
Additional Situations for Self-Billed e-Invoicing:
- Interest payments, except:
- Interest payments to a related company (as defined in the Income Tax Act 1967) incorporated in Malaysia that provides centralized treasury services to its related companies
- Late payment interest or charges imposed by Malaysian taxpayers
- Payments related to:
- Capital reduction
- Share/capital/unit redemption
- Share buyback
- Return of capital
- Liquidation proceeds
Timing of Self-Billed e-Invoice Issuance for Claims, Compensation, or Benefit Payments from an Insurer's Insurance Business
| Condition |
Date of Issuance |
| If there is a written agreement |
If no approval is required from the government or state government, the date of issuance will be the date of the agreement. |
| If government or state government approval is required |
The date of issuance will be the date of such approval. If the approval is conditional, the date of issuance will be the date on which the last condition is satisfied. |
| If there is no written agreement |
The date of issuance will be the date of completion. |
(Refer to LHDN website e-invoices Sepecific Guideline, Section 8, https://www.hasil.gov.my/media/uwwehxwq/irbm-e-invoice-specific-guideline.pdf)
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