LHDNM e Invoice General Faqs
LHDNM e Invoice General Faqs
1. What is an e-Invoice?
2. What is the e-Invoice file format acceptable by IRBM for validation purposes?
 The e-Invoice must be generated in the form of XML or JSON file format, in accordance with
 the requirements outlined by the IRBM. Refer to e-Invoice Software Development Kit (SDK)
 Microsite via the following link - https://sdk.myinvois.hasil.gov.my for the sample of XML / JSON.
 4. Are taxpayers allowed to continue claiming for tax deduction / personal tax relief without an
    e-Invoice?
 Yes, taxpayers can continue to claim tax deductions or personal tax relief using existing
 documentation until such time the legislation has been amended.
 No, the issuance of e-Invoice is not limited to only transactions within Malaysia. It is also
 applicable for cross-border transactions.
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6. Are all businesses required to issue e-Invoice?
Yes, all taxpayers undertaking commercial activities in Malaysia are required to issue
e-Invoice, in accordance with the phased mandatory implementation timeline. Refer to Section
1.5 of the e-Invoice Guideline for further details.
7. Are all industries included in the e-Invoice implementation? Are there any industries
   exempted?
Currently, there are no industries that are exempted from the e-Invoice implementation.
Note that certain persons and types of income and expense are exempted from e-Invoice
implementation. Refer to Section 1.6 of the e-Invoice Guideline for further details.
8. 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 is also required to obtain
its own tax identification number (TIN) to meet its e-Invoice obligations.
All taxpayers are required to implement e-Invoice. e-Invoice will be implemented in phases
according to annual turnover or revenue thresholds as stated in the statement of comprehensive
income in the Financial Year 2022 Audited Financial Statements.
Refer to Section 1.5 of the e-Invoice Guideline for further details.
10. Has there been any change to the mandatory implementation date for taxpayers with an
    annual turnover or revenue exceeding RM100 million due to the release of Income Tax
    (Issuance of Electronic Invoice) Rules 2024 [P.U. (A) 265] on 30 September 2024? If so,
    what is the revised mandatory implementation date for these taxpayers?
The Income Tax (Issuance of Electronic Invoice) Rules 2024 [P.U. (A) 265] has been gazetted
effective from 1 October 2024. The rules are issued in accordance with the power conferred to
Minister to prescribe a person to issue an e-Invoice and the particulars to be included in the
e-Invoice.
The prescribed mandatory implementation date of 1 October 2024 for taxpayers with an annual
turnover or revenue of more than RM100 million specifically relates to the period when
enforcement actions for non-compliance may be initiated by the IRBM against such taxpayers.
In other words, any penalty for non-compliance, should they arise, will only be imposed starting
from 1 October 2024.
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The mandatory implementation date as outlined in Section 1.5 of the e-Invoice Guideline
remains unchanged.
11. If my business is in operation as at year of assessment (YA) 2022 and my annual revenue
    did not reach RM500,000 in YA2022, how should I determine my e-Invoice implementation
    date?
(a) Taxpayers that are able to meet the e-Invoice exemption criteria (please refer Part 3:
    e-Invoice for MSME of this FAQ for more details on the criteria)
    • The taxpayer will fall under Phase 5 (i.e., e-Invoice implementation starting from 1 July
        2026) as the taxpayer’s YA2022 annual turnover or revenue did not exceed RM1 million.
        However, since the taxpayer fulfilled the criteria to be exempted, the taxpayer is exempt
        from implementation of e-Invoice (including the self-billed e-Invoice requirements).
   •   If the taxpayer’s annual turnover or revenue subsequently reached / exceeded
       RM500,000 in YA2023, YA2024 or YA2025, the taxpayer is required to implement
       e-Invoice starting from 1 July 2026.
   •   If the taxpayer’s annual turnover or revenue reaches / exceeds RM500,000 in YA2026
       or thereafter, the taxpayer is required to implement starting from 1 January in the second
       year following the YA in which the total annual turnover or revenue reaches / exceeds
       RM500,000.
(b) Taxpayers that are not able to meet the e-Invoice exemption criteria (please refer Part 3:
    e-Invoice for MSME of this FAQ for more details on the criteria)
   •   The taxpayer will fall under Phase 5 (i.e., e-Invoice implementation starting from 1 July
       2026) as the taxpayer’s YA2022 annual turnover or revenue did not exceed RM1 million.
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       Since the exemption criteria were not met, the taxpayer is required to implement
       e-Invoice starting from 1 July 2026.
The following example is provided for ease of understanding:
Mountain Jump Sdn Bhd closes its financial year on 31 December every year. Mountain Jump
Sdn Bhd is an independent company with no corporate shareholders. In YA2022 (i.e., 1 January
2022 to 31 December 2022), Mountain Jump Sdn Bhd recorded an annual revenue of
RM400,000. As Mountain Jump Sdn Bhd’s annual revenue is below the RM500,000 threshold
and it fulfilled the criteria to be exempted, Mountain Jump Sdn Bhd is exempt from implementing
e-Invoice.
However, in YA2024 (i.e., 1 January 2024 to 31 December 2024), Mountain Jump Sdn Bhd has
recorded an annual revenue of RM620,000. As Mountain Jump Sdn Bhd’s annual revenue has
exceeded the exemption threshold, Mountain Jump Sdn Bhd is required to implement e-Invoice
starting from 1 July 2026.
12. If my business commenced operation from YA2023 to YA2025, how should I determine my
    e-Invoice implementation date?
(a) Taxpayers with annual turnover or revenue of at least RM500,000 in YA2023, YA2024 or
    YA2025
   •   As the taxpayer’s annual turnover or revenue reached / exceeded RM500,000 in
       YA2023, YA2024 or YA2025, the taxpayer is required to implement e-Invoice starting
       from 1 July 2026.
       Example: Layang Warna Sdn Bhd was incorporated on 1 October 2023 and commenced
       operations on the same date, closing its accounts on 30 September each year. It is an
       independent company with no corporate shareholders.
       In YA2024 (i.e., 1 October 2023 to 30 September 2024), Layang Warna Sdn Bhd
       recorded an annual revenue of RM525,000. As Layang Warna Sdn Bhd’s annual
       revenue has exceeded the exemption threshold, Layang Warna Sdn Bhd is required to
       implement e-Invoice starting from 1 July 2026.
(b) Taxpayers with annual turnover or revenue of less than RM500,000 in YA2023, YA2024 and
    YA2025 who are able to meet the e-Invoice exemption criteria (please refer Part 3: e-Invoice
    for MSME of this FAQ for more details on the criteria)
   •   The taxpayer will fall under Phase 5 (i.e., e-Invoice implementation starting from 1 July
       2026) as the taxpayer’s YA2023, YA2024 and YA2025 annual turnover or revenue did
       not exceed RM1 million. However, since the taxpayer fulfilled the criteria to be exempted,
       the taxpayer is exempt from implementation of e-Invoice (including self-billed e-Invoice
       requirements).
   •   If the taxpayer’s annual turnover or revenue subsequently reached / exceeded
       RM500,000 in YA2026 onwards, the taxpayer is required to implement starting from 1
       January in the second year following the YA in which the total annual turnover or revenue
       reaches RM500,000.
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       Example: Pak Salleh started its sole proprietorship business, Kedai Runcit Salleh, on 1
       January 2025. In YA2025 (i.e., 1 January 2025 to 31 December 2025), Pak Salleh
       records an annual revenue of RM185,000. As Pak Salleh’s annual revenue is recorded
       below the RM500,000 threshold and the criteria to be exempted have been fulfilled, Pak
       Salleh is exempted from implementing e-Invoice.
       However, in YA2027 (i.e., 1 January 2027 to 31 December 2027), Pak Salleh records
       an annual revenue of RM570,000. As Pak Salleh’s annual revenue has exceeded the
       exemption threshold, Pak Salleh is required to implement e-Invoice starting from 1
       January in the second year following the YA in which the total annual turnover or revenue
       reaches RM500,000 (i.e., 1 January 2029).
(c) Taxpayers with annual turnover or revenue of less than RM500,000 in YA2023, YA2024 and
    YA2025 who are not able to meet the e-Invoice exemption criteria (please refer Part 3:
    e-Invoice for MSME of this FAQ for more details on the criteria)
   •   The taxpayer will fall under Phase 5 (i.e., e-Invoice implementation starting from 1 July
       2026) as the taxpayer’s YA2023, YA2024 and YA2025 annual turnover or revenue did
       not exceed RM1 million. Since the exemption criteria were not met, the taxpayer is
       required to implement e-Invoice starting from 1 July 2026.
       Example: Paper Bottle Sdn Bhd, a wholly-owned subsidiary of Paper All Berhad that has
       implemented e-Invoice, was incorporated on 1 April 2023 and commenced operations
       on the same date, closing its accounts on 31 March each year.
       In YA2024 (i.e., 1 April 2023 to 31 March 2024) and YA2025 (i.e., 1 April 2024 to 31
       March 2025), Paper Bottle Sdn Bhd recorded annual revenue of RM230,000 and
       RM365,000 respectively. Even though Paper Bottle Sdn Bhd’s annual revenue did not
       exceed the exemption threshold, the exemption criteria were not met. In this case, Paper
       Bottle Sdn Bhd is required to implement e-Invoice starting from 1 July 2026.
13. If my business commences operation from YA2026 onwards, how should I determine my
    e-Invoice implementation date?
(a) Taxpayers that are not able to meet the e-Invoice implementation exemption criteria (please
    refer Part 3: e-Invoice for MSME of this FAQ for more details on the criteria)
   •   The taxpayer is required to implement e-Invoice starting from 1 July 2026 or upon the
       operation commencement date, whichever later, as the exemption criteria are not met.
       Example: Coco Boss Sdn Bhd is a company principally engaged in the business of cocoa
       plantation and it has implemented e-Invoice since 1 August 2024. Coco Boss Sdn Bhd
       has established a new subsidiary, Coco Lock Sdn Bhd, on 1 September 2026. Coco
       Lock Sdn Bhd commenced operations immediately, on the same day of incorporation.
       As the exemption criteria were not met, Coco Lock Sdn Bhd is required to implement
       e-Invoice starting from its operation commencement date (i.e., 1 September 2026).
(b) Taxpayers that are able to meet the e-Invoice implementation exemption criteria (please
    refer Part 3: e-Invoice for MSME of this FAQ for more details on the criteria)
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     •   As the exemption criteria are being met, the taxpayer is required to implement e-Invoice
         starting from 1 January in the second year following the YA in which the total annual
         turnover or revenue reaches RM500,000.
     •   If the taxpayer’s annual turnover or revenue for the first YA (i.e., YA2026) has reached /
         exceeded RM500,000, the taxpayer is required to implement starting from 1 January in
         the second year following the YA in which the total annual turnover or revenue reaches
         RM500,000.
     •   However, if the taxpayer’s annual turnover or revenue for the first YA (i.e., YA2026) did
         not exceed RM500,000, the taxpayer is exempt from implementation of e-Invoice.
         Subsequently, if the taxpayer’s annual turnover or revenue reached / exceeded
         RM500,000 in YA2027 or thereafter, the taxpayer is required to implement starting from
         1 January in the second year following the YA in which the total annual turnover or
         revenue reaches RM500,000.
         Example: The operations of Warung Salima, owned and run by Puan Salima,
         commenced on 1 January 2026. In YA2026 (i.e., 1 January 2026 to 31 December 2026),
         Puan Salima records an annual revenue of RM512,000. As Puan Salima’s annual
         revenue has exceeded the RM500,000 threshold, Puan Salima is required to implement
         e-Invoice starting from 1 January in the second year following the YA in which the total
         annual turnover or revenue reaches RM500,000 (i.e., 1 January 2028).
         Example: Adjacent to Warung Salima, Mak Cik Samsiah started her sole proprietorship
         business, Pinggan Mangkuk Enterprise, on same date (i.e., 1 January 2026). However,
         for YA2026 (i.e., 1 January 2026 to 31 December 2026), Mak Cik Samsiah records an
         annual revenue of RM308,000. As Mak Cik Samsiah’s annual revenue is recorded below
         the RM500,000 threshold and the criteria to be exempted have been fulfilled, Mak Cik
         Samsiah is exempted from implementing e-Invoice.
         In YA2027 (i.e., 1 January 2027 to 31 December 2027), Mak Cik Samsiah records an
         annual revenue of RM540,000. As Mak Cik Samsiah’s annual revenue has exceeded
         the exemption threshold, Mak Cik Samsiah is required to implement e-Invoice starting
         from 1 January in the second year following the YA in which the total annual turnover or
         revenue reaches RM500,000 (i.e., 1 January 2029).
14. How can taxpayers start preparing for the e-Invoice implementation?
 When implementing e-Invoice, the three (3) primary factors to consider are:
 •   Human resources: Businesses are advised to assemble a dedicated team equipped with
     the necessary expertise and capabilities to prepare for the implementation.
 •   Business processes: Conduct a comprehensive review of the current process and
     procedures in issuing invoice transaction documents.
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•   Technology and systems: Confirm the availability of the necessary resources, data
    structures and existing IT capabilities to ensure the systems in place comply with the
    e-Invoice requirements.
IRBM is actively conducting a series of engagement sessions with industry players, tax
practitioners, professional bodies and identified stakeholders to provide comprehensive
information regarding the implementation of e-Invoice in Malaysia including:
a) Sharing the planning of action plans, strategies, and status developments regarding the
   implementation of e-Invoice; and
b) Obtaining feedback and views through two-way communication between IRBM and
   taxpayers on the implementation of e-Invoice.
Taxpayers may also contact their respective IRBM state offices to request for engagement
sessions.
16. Who should we reach out to if there are any queries or concerns?
You may contact us through the following channels for any queries or concerns regarding:
a) The e-Invoice implementation in Malaysia: myinvois@hasil.gov.my
b) Any enquiries (e.g.: Software Development Kit (SDK)): MyInvois Customer Feedback Form
   at https://feedback.myinvois.hasil.gov.my
Alternatively, taxpayers may reach out to the e-Invois HASiL Help Desk Line at 03-8682 8000,
available 24 hours a day, from Monday to Sunday OR chat with us via the MyInvois Live Chat
at https://www.hasil.gov.my/en/e-invoice/contact-us.
17. Are there any incentives provided to taxpayers for the implementation of e-Invoice?
The Malaysian government has announced the following tax incentives or grants in relation to
implementation of e-Invoice during Budget 2024.
Tax deduction of up to RM50,000 for each year of assessment given on environmental, social
and governance related expenditure, including consultation fee for the implementation of
e-Invoice incurred by Micro, Small, and Medium Enterprises (MSMEs), effective from year of
assessment 2024 to year of assessment 2027.
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PART 2: SCOPE AND PROCESS
(i) General
 18. For transactions conducted in foreign currencies, are we required to convert it into Ringgit
     Malaysia (RM) equivalent (RM-equivalent) when issuing an e-Invoice / self-billed
     e-Invoice?
 e-Invoice can be displayed in any currency, including RM. Unless there are legal or tax
 requirements to include the RM-equivalent, taxpayers can issue the e-Invoice in foreign
 currency. Refer to Section 13 of the e-Invoice Specific Guideline for further details.
 19. Do buyers need to issue self-billed e-Invoices to record expenses when dealing with
     suppliers located in rural areas with poor internet connectivity?
 Kindly note that self-billed e-Invoice is only allowed for certain transactions as stated under
 Section 8 of the e-Invoice Specific Guideline.
 Businesses who are facing poor internet connectivity and lack infrastructure to issue e-Invoice
 are advised to approach the nearest IRBM state office for further discussions.
20. Can I issue self-billed e-Invoice if my supplier did not issue e-Invoice to me?
 Issuance of self-billed e-Invoice is only permitted for circumstances that are provided under
 Section 8.3 of the e-Invoice Specific Guideline.
 Where the transaction does not fall within Section 8.3 of the e-Invoice Specific Guideline,
 taxpayers are not allowed to issue self-billed e-Invoice.
 21. Can I issue self-billed e-Invoice for any circumstance that is not listed under Section 8.3
     of the e-Invoice Specific Guideline?
 No, please note that issuance of self-billed e-Invoice is only permitted for circumstances that
 are provided under Section 8.3 of the e-Invoice Specific Guideline.
 22. Do taxpayers need to include the details of sales tax exemption under Schedule 3 of the
     Sales Tax (Person Exempted from Payment of Tax) Order 2018 (i.e., C3 exemption
     approval number) in the ‘Details of Tax Exemption’ data field when issuing e-Invoice / self-
     billed e-Invoice?
 Further to harmonisation with Royal Malaysian Customs Department (RMCD), taxpayers are
 required to input the C3 details when issuing e-Invoice or self-billed e-Invoice, as the case
 may be.
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(ii) Details of Supplier and Buyer
 23. Are the buyers required to provide their relevant details to the supplier for the issuance of
     e-Invoices?
 Yes, where the buyers request for an e-Invoice to be issued, the buyers are required to share
 their details to the supplier for the purposes of issuing e-Invoice.
24. Which TIN should individual taxpayers use for the purposes of e-Invoice?
 For the purposes of e-Invoice, individual taxpayers should provide TIN with prefix of “IG”.
 Please refer to Section 2.3.1.1 of the e-Invoice Guideline for more details on how to retrieve
 and verify TIN.
 25. How do taxpayers issue an e-Invoice to a non-TIN holder such as foreign (non-Malaysian)
     buyers?
 Suppliers are required to obtain buyer’s details from the foreign buyers for the purposes of
 e-Invoice issuance.
 In relation to TIN to be input in the e-Invoice, supplier may use “EI00000000020” for foreign
 buyers without TIN. Refer to Section 10.5 of the e-Invoice Specific Guideline for further details.
 26. For the purposes of issuing e-Invoice / self-billed e-Invoice, can the Malaysian taxpayers
     default the TIN of the foreign supplier / foreign buyer to be general TIN, regardless of
     whether the foreign supplier / foreign buyer has a specific TIN assigned by the IRBM?
 It is the taxpayers’ responsibility to verify with their foreign supplier / foreign buyer on the
 availability of TIN. The general TIN provided is to ease taxpayers in issuing e-Invoice / self-
 billed e-Invoice in the case where the said foreign supplier / foreign buyer does not have a
 TIN assigned by the IRBM.
 27. Should taxpayers register with Companies Commission of Malaysia (SSM) input both the
     old and new business registration number when issuing an e-Invoice?
 Taxpayers registered with SSM are required to input the new business registration number
 (12-digit characters) for the purposes of e-Invoice issuance.
 However, IRBM understand that there have been some difficulties for taxpayers to provide
 the new business registration number from SSM, resulting in validation failures. In response,
 IRBM has taken a step to temporarily disable the business registration number validation
 requirement from the e-Invoice submission process, effective from 19 July 2024.
 28. If taxpayers are not register with SSM, what are the information that the taxpayer should
     input for business registration number when issuing an e-Invoice?
 For taxpayers that are registered with other authority / body, the taxpayers are required to
 input the relevant registration number.
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(iii) Issuance of e-Invoices
 29. Do businesses need to submit an e-Invoice within the same day the transaction is being
     made?
 There is no specific requirement on the timing of e-Invoice issuance, except in specific cases
 such as consolidated e-Invoice, self-billed e-Invoice for importation of goods / services and
 e-Invoice for foreign income.
 •   For consolidated e-Invoice, suppliers are required to issue the consolidated e-Invoice
     within seven (7) calendar days after the month end.
 •   For self-billed e-Invoice for importation of goods, the Malaysian purchasers are required
     to issue self-billed e-Invoice latest by the end of the second month following the month of
     customs clearance is obtained.
 •   For self-billed e-Invoice for importation of services, the Malaysian purchasers are required
     to issue self-billed e-Invoice latest by the end of the month following the month upon (1)
     payment made by the Malaysian purchaser; or (2) receipt of invoice from foreign supplier,
     whichever earlier. The determination of the aforementioned (1) and (2) is in accordance
     with the prevailing rules applicable for imported taxable service.
 •   For e-Invoice for foreign income, the suppliers (i.e., income recipients) are required to
     issue the e-Invoice latest by the end of the month following the month of receipt of the said
     foreign income.
 Where any specific legislation is applicable, you may proceed to follow as per the said
 legislation.
 30. Are businesses allowed to issue consolidated e-Invoice for all types of transactions where
     the Buyers do not require an e-Invoice?
 Yes, the supplier is allowed to issue consolidated e-Invoice for transactions where no request
 for e-Invoice has been made by the buyer, regardless of business-to-business (B2B),
 business-to-consumer (B2C) or business-to-government (B2G) transactions, except for
 transactions / activities listed under Section 3.7 of the e-Invoice Specific Guideline.
 31. Does the MyInvois Portal allow for e-Invoice to be created and stored in draft form prior to
     finalisation and issuance?
 Yes, the supplier will be able to create e-Invoice in draft or proforma. e-Invoice will only be
 accepted once the validation is successful.
 Failure to issue e-Invoice is an offence under Section 120(1)(d) of the Income Tax Act 1967
 and will result in a fine of not less than RM200 and not more than RM20,000 or imprisonment
 not exceeding 6 months or both, for each non-compliance.
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(iv) Validation of e-Invoices
 The e-Invoice validation by IRBM will be done in near real-time, generally in less than two (2)
 seconds. Refer to Section 3.8 of the e-Invoice Specific Guideline for further details.
 IRBM validation includes a series of checks to ensure the e-Invoice submitted to IRBM
 conforms to the e-Invoice format and data structure as specified by IRBM. Refer to the
 e-Invoice SDK Microsite for further details.
 35. Will the supplier’s invoice number remain in the invoice document or will a different invoice
     number be assigned by IRBM upon the return of the validated e-Invoice to the supplier?
 The supplier’s invoice number will remain as a separate field in the same invoice document
 for the purpose of the supplier’s internal reference and tracking.
 Upon validation, the IRBM will assign a Unique Identifier Number to each e-Invoice.
 36. Does IRBM provide a standard visual representation template for suppliers to share the
     e-Invoices to buyers upon IRBM’s validation?
 Taxpayers are allowed to adopt any format for the visual representation of the e-Invoice as
 per current practice, provided the QR code is embedded accordingly.
 37. Is the issuer required to share the validated e-Invoice or visual representation of the
     e-Invoice?
 IRBM acknowledges that there may be practical challenges in sharing the validated e-Invoice
 (in the form of XML / JSON file). Therefore, until further notice, the IRBM allows taxpayers to
 share either the validated e-Invoice or a visual representation of the validated e-Invoice, or
 both.
 38. Does the MyInvois Portal allow for editing of information after the e-Invoice has been
     validated by IRBM?
 No, the supplier would need to cancel the e-Invoice within 72 hours from time of validation
 and reissue a new e-Invoice.
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Any changes after 72 hours from time of validation would require the supplier to issue a new
e-Invoice (i.e., debit note, credit note, refund note e-Invoice) to adjust the original e-Invoice
issued. Thereafter, a new e-Invoice would be required to be issued accordingly.
39. Is there any adjustment window allowed to the supplier to cancel an invoice submitted to
    IRBM?
Yes, there is a 72-hour timeframe for the e-Invoice to be cancelled by the supplier. Refer to
sections 2.3.6 or 2.4.5 of the e-Invoice Guideline for further details.
40. If the issuer accidentally made a mistake or an information was provided inaccurately
    during the issuance of e-Invoice / self-billed e-Invoice, how should the issuer rectify this
    mistake if the issuer notices the mistake within 72-hour from time of validation of the said
    e-Invoice / self-billed e-Invoice?
The issuer is allowed to cancel the e-Invoice issued and validated by IRBM within 72 hours
from the time of validation, and subsequently reissue a new e-Invoice.
41. Following the above scenario, if the issuer does not want to cancel the e-Invoice but
    decides to issue a credit note / debit note / refund note e-Invoice to make adjustment, will
    this be allowed?
Yes, the issuer is allowed to issue a credit note / debit note / refund note e-Invoice to reflect
the necessary adjustment to the original e-Invoice, even if the 72-hour timeframe has not
elapsed. Kindly note to include the Unique Identifier Number of the affected original e-Invoice
under the “Original e-Invoice Reference Number” field in the issuance of credit note / debit
note / refund note e-Invoice.
42. Following the above scenario, if the issuer notices the mistake only in the following week,
    how should the issuer rectify the mistake in this case?
In event where the mistake was noticed and/or any amendment is required on the e-Invoice
issued after the 72-hour timeframe, the issuer is required to reflect the amendments /
adjustment by way of issuing a credit note / debit note / refund note e-Invoice.
Kindly note to include the Unique Identifier Number of the affected original e-Invoice under
the “Original e-Invoice Reference Number” field in the issuance of credit note / debit note /
refund note e-Invoice.
43. What is the timeframe to issue e-Invoice adjustments (i.e., debit note, credit note and
    refund note) after the 72-hours validation period?
There is no timeframe restriction for suppliers to issue e-Invoice adjustments. Taxpayers may
follow their respective company policy for any e-Invoice adjustments.
As foreign suppliers and/or buyers generally do not use MyInvois System, any e-Invoice
adjustments would be done through issuance of debit note, credit note, and refund note
e-Invoice.
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 44. Can taxpayers issue one (1) credit note e-Invoice to adjust multiple original e-Invoices?
 Yes, taxpayers can make adjustments to multiple original e-Invoices by issuing one (1) single
 credit note / debit note / refund note e-Invoice, as the case may be. Note that adjustments can
 also be made to consolidated e-Invoices.
 Where multiple original e-Invoices are being adjusted in the same credit note / debit note /
 refund note e-Invoice, the IRBM Unique Identifier Number of each original e-Invoice must be
 indicated in the ‘Original e-Invoice Reference Number’ data field. Taxpayers who are
 transmitting via API are reminded to refer to the SDK for the appropriate code to be input.
 If adjustments are to be made to original invoices that were issued prior to the implementation
 of e-Invoice (i.e., no IRBM Unique Identifier Number has been assigned), taxpayers are then
 allowed to input “NA” in the ‘Original e-Invoice Reference Number’ data field.
 Yes, a refund note e-Invoice is required for return of monies to buyers, with the following
 exception:
  1. Payment made wrongly by buyers
  2. Overpayment by buyers
  3. Return of security deposits
 46. Prior to full implementation, there may be suppliers who do not issue e-Invoice as they
     have not reached the mandatory implementation phase / date. In this situation, will IRBM
     accept normal invoices issued by these suppliers?
 The compliance obligation of issuing e-Invoice lies with the Supplier (or the Buyer in the case
 of self-billed e-Invoice). As such, during the transitional period, taxpayers will be allowed to
 provide either normal bill / receipt / invoice (if the Supplier has yet to implement e-Invoice in
 accordance with the implementation timeline) or validated e-Invoice to substantiate a
 transaction for tax purposes until full implementation of e-Invoice.
 47. Which types of income fall into the scope for e-Invoice, considering taxpayers may have
     a range of income sources of contributing to their annual turnover (e.g., interest income,
     investment income, gains from investment disposal)?
 e-Invoice is required for all types of income and expenses, excluding certain types as outlined
 in the e-Invoice General Guideline and e-Invoice Specific Guideline.
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Kindly note that the abovementioned exemptions are subject to periodic review and updates.
In cases where the deposit is refundable, the issuance of e-Invoice is not required. However,
if the deposit is non-refundable, issuance of e-Invoice is required.
Where the Director has entered into contract for service, the Director is required to issue
e-Invoice to the company for any income received.
However, where the Director has entered into contract of service, the fees are considered as
part of employment income. Currently, this is being exempted from issuance of e-Invoice as
per the e-Invoice Guideline. Kindly note that the exemptions are subject to periodic review
and updates.
An e-Invoice may be required for disbursements and reimbursements, subject to the situation.
Refer to Section 5 of the e-Invoice Specific Guideline for further details.
52. Is e-Invoice required for inter-department / inter-division transactions within the same
    company?
53. Is an individual landlord required to issue e-Invoice to the tenant for rental of property?
54. How should the tenant substantiate its payment of utility expenses if the utility bills are
    issued in the landlord’s name?
Where the tenant is unable to request for the utility bills to be issued in his name, such utilities
paid by the tenant should be included in:
•   the e-Invoice issued by the landlord (if the landlord is conducting a business); or
                                                15
•   the self-billed e-Invoice issued by the tenant (if the landlord is not conducting a business),
as the case may be.
55. In a consignment arrangement where the consignee pays the consignor for the goods
    consigned at their premises only when the goods are sold / consumed. In this case, when
    should an e-Invoice be issued?
The consignor (supplier in this case) should issue the e-Invoices to the consignee (buyer in this
case) upon sale / consumption of goods by the consignee, in accordance with the current
consignor’s practice in issuing invoices.
56. Should self-billed e-Invoice on payment to agents, dealers and distributors be done on an
    accrual or paid basis?
The issuance of self-billed e-Invoices on payments to agents, dealers, and distributors can be
done on either an accrual basis or paid basis, as long as this is consistently applied and in line
with the documentation provided to the agents (e.g., statements).
57. For certain corporate agents where the existing process includes the issuance of invoice to
    the company, can the current process of the corporate agent issuing the e-Invoice be
    maintained instead of being under self-billed e-invoice?
Buyer (i.e., taxpayer that makes payment to agents, dealers and distributors) is required to
issue self-billed e-Invoice for payments or any other incentives (whether in monetary form or
otherwise made) to the agent, dealers and distributors as outlined under Section 9.4 of the
e-Invoice Specific Guideline.
This requirement applies regardless of whether the agents, dealers and distributors are
individual or corporate (i.e., supplier in this case). The buyer is obliged to share validated self-
billed e-Invoice with the supplier upon validation.
In this regard, the agents, dealers and distributors are not required to issue an e-Invoice to the
taxpayers who make payment.
58. For monetary incentive payments, can self-billed e-Invoice be done based on the periodic
    statements provided to agents?
Yes, self-billed e-Invoices can be issued based on the periodic statements provided to agents
following current practice / frequency (e.g., bi-weekly, monthly etc.). The appropriate
classification code should be input in the self-billed e-Invoice.
                                                16
59. As the invoices / statements currently do not contain non-monetary incentive payments
    (e.g., incentive trips, gifts, etc.) and this information is typically only available during the
    preparation of the annual CP58, can the data for non-monetary incentives be transmitted
    upon the availability of such information (i.e., annually)?
Yes, it is acceptable to transmit the information for non-monetary incentive payments annually
if such information is only available during the preparation of the annual CP58.
However, if such information is available on accrual or payment basis, or upon issuance of
periodic invoices / statements provided to agents, dealers and distributors, it should be
transmitted to IRBM in the self-billed e-Invoice with the same frequency.
The appropriate classification code should be input in the self-billed e-Invoice.
60. Can the self-billed e-Invoice be issued on a net basis (gross amount minus reversals), which
    matches the total amount paid as presented in the statements to agents?
Yes, a self-billing arrangement can be done on a net commission basis (gross amount minus
reversals), provided the line details of the commission reversals are being included in the self-
billed e-Invoice.
 Scenario 1: Net commission paid to agent         The line details of the commission reversal
                                                  in Feb 2025 needs to be included in the self-
   Jan 2025                    Amount (RM)        billed e-Invoice.
   Commission payable                 3,000       Self-billed e-Invoice will be issued on
   for Jan 2025                                   monthly basis (in accordance with current
   Actual payment to                  3,000       issuance frequency):
   agent in Jan 2025                              •   RM3,000 for Jan 2025
                                                  •   RM1,000 for Feb 2025
   Feb 2025                    Amount (RM)
   Commission payable                 2,000
   for Feb 2025
   Less: Clawback /                   (1,000)
   reversal        of
   commission for Jan
   2025
   Actual payment to                   1,000
   agent in Feb 2025
                                                17
Scenario 2: Clawback is more than the     Self-billed credit note is required to be issued
commission payable                        for any monetary and non-monetary
                                          incentives payable to agents, irrespective of
  Jan 2025                Amount (RM)     whether the actual payment is nil.
  Commission payable           3,000      Self-billed e-Invoice will be issued on monthly
  for Jan 2025                            basis (in accordance with current issuance
  Actual payment to            3,000      frequency):
  agent in Jan 2025                       •   RM3,000 for Jan 2025
                                          •   (RM1,000) for Feb 2025
  Feb 2025                Amount (RM)
                                          •   RM2,000 for Mar 2025
  Commission payable           2,000
  for Feb 2025
  Less: Clawback /             (3,000)
  reversal        of
  commission for Jan
  2025
  Actual payment to                Nil
  agent in Feb 2025
                                         18
  Scenario 3: No payment to individual            The self-billed e-Invoice should include only
  agents due to set-off of expenses               monetary and non-monetary incentives
                                                  payable to agents.
    Jan 2025                   Amount (RM)
                                                  In cases where rental is charged to an agent,
    Commission payable                 3,000      a separate e-Invoice is required to be issued
    for Jan 2025                                  by the company, as this does not constitute a
    Less: Rental charged              (3,500)     part of the incentive payments.
    by company to agent                           Self-billed e-Invoice will be issued on monthly
    Actual payment to                    Nil      basis (in accordance with current issuance
    agent in Jan 2025                             frequency):
                                                  •   RM3,000 for Jan 2025
    Feb 2025                   Amount (RM)        •   RM3,500 for Jan 2025 rental
    Commission payable                 3,000      •   RM3,000 for Feb 2025
    for Feb 2025
    Less: Rental charged                (500)
    by company to agent
    Actual payment to                  2,500
    agent in Feb 2025
 The issuance of self-billed e-Invoices on interest can be done on either an accrual basis or paid
 basis.
(ix) e-Invoice treatment for vouchers, gift cards and loyalty points
Note that this applies to both monetary vouchers (e.g., gift card, token, stamp (other than postage
stamp), credit reload etc.) and non-monetary vouchers (i.e., voucher / coupon which displays the
specific goods or services that can be redeemed).
 In cases where the voucher is given for free or is refundable in nature, no e-Invoice is required to
 be issued. However, if the voucher sold is non-refundable, issuance of e-Invoice is required.
                                                19
 63. Is e-Invoice required to be issued for expired vouchers?
 Where the free vouchers or non-refundable vouchers sold (where an e-Invoice has been issued)
 have expired, no e-Invoice is required to be issued upon expiry. However, where the refundable
 vouchers have expired, issuance of e-Invoice is required upon expiry.
 Yes, taxpayers are required to issue e-Invoice upon utilisation of the refundable vouchers.
 However, as the vouchers are refundable in nature (where no e-Invoice has been issued),
 taxpayers are required to ensure that the “Total Excluding Tax” at invoice level matches the total
 sales for the transaction. Taxpayers may include the refundable vouchers in the “prepayment”
 field, as this is an optional field.
 Yes, taxpayers are required to issue e-Invoice upon utilisation of the non-refundable vouchers.
 However, as the vouchers are non-refundable in nature (where e-Invoice has been issued),
 taxpayers are required to ensure that the “Total Excluding Tax” at invoice level matches the
 amount of sales not settled by the non-refundable vouchers. Taxpayers should include the non-
 refundable vouchers in a separate invoice line.
 66. Do we need to issue e-Invoice for the purchase-with-purchase vouchers given to buyers upon
     certain spending threshold has been met or fulfilling certain conditions? Do we also need to
     issue e-Invoice for goods sold / services rendered that are settled by the purchase-with-
     purchase vouchers?
 No e-Invoice is required to be issued for the purchase-with-purchase voucher, if the said voucher
 is provided for free.
 For the e-Invoice treatment for expired vouchers and vouchers redemption, please refer to the
 earlier questions under (ix) Vouchers, gift cards and loyalty points in Part 2: Scope and Process
 e-Invoice.
 67. For the purposes of issuing self-billed e-Invoices for purchases from foreign supplier, can the
     Malaysian buyer consolidate all invoices received from the same foreign supplier?
 No. At this juncture, a separate self-billed e-Invoice must be issued for each individual
 transactions, save for exceptions listed under section 3.6.5 of the e-Invoice Specific Guideline.
                                                20
68. Are Malaysian buyers required to include the import duty and/or sales tax levied by the RMCD
    upon customs clearance on imported goods when issuing self-billed e-Invoice?
No, Malaysian buyers are not required to include the duties and/or taxes levied by the RMCD in
the self-billed e-Invoice.
69. Does e-Invoice comply with RMCD documents for RMCD clearance? Can the visual
    representation of e-Invoice be used for RMCD clearance and/or other RMCD purposes?
e-Invoice requirements as outlined in Appendix 1 of the e-Invoice Guideline have taken into
consideration the information required by both IRBM and RMCD. Both IRBM and RMCD may use
the e-Invoice for tax purposes.
However, note that existing documents required by RMCD for RMCD clearance would still apply.
Where the visual representation of e-Invoice contains all the information required by Sales Tax or
Service Tax (SST) acts / regulations / guidelines, the taxpayers should be allowed to use the
same visual representation for SST purposes.
70. For the purposes of self-billed e-Invoice on importation of goods, which goods value should
    the taxpayers adopt?
Taxpayer is required to input the actual transaction value incurred as stated in the foreign
supplier’s invoice for e-Invoice purposes.
Where applicable, taxpayer may include the extra charges applicable as per the agreed incoterms
under “Details of other charges” field.
71. In relation to acquisition of goods from foreign suppliers, when will the Malaysian buyers be
    required to issue a self-billed e-Invoice?
The Malaysian buyers are required to issue a self-billed e-Invoice latest by the end of the
second month following the month of RMCD’s clearance is obtained on the imported goods. The
buyers should include the appropriate details as listed in the self-billed e-Invoice annexure on
importation of goods.
                                              21
72. Where the imported goods are purchased under one foreign supplier’s invoice but imported
    into Malaysia via multiple shipments (with different RMCD’s clearance dates), when will the
    Malaysian buyer be required to issue self-billed e-Invoice?
Where there are multiple import clearances under the same invoice from the foreign supplier, the
timing for the issuance of the self-billed e-Invoice are as follows:
a) If the foreign supplier’s invoice is issued by the time the first import shipment clearance
   is obtained
   •     The Malaysian buyer is required to issue self-billed e-Invoice based on the foreign
         supplier’s invoice as per the timing of issuance outlined under Section 10.4.8 of the
         e-Invoice Specific Guideline (i.e., latest by the end of the second month following the
         month of RMCD’s clearance is obtained). The Malaysian buyer is required to input the
         customs form reference number (e.g., Customs Form No.1) in the self-billed e-Invoice.
   •     No self-billed e-Invoice is required to be issued for the subsequent shipments for goods
         that are included within the same foreign supplier’s invoice.
   •     As an example, Company ABC Sdn Bhd has purchased 4,000 units of machinery from
         DEF Ltd in China. The machineries will be imported into Malaysia via four separate
         shipments. The issuance of self-billed e-Invoice shall be as follows:
       Shipment 1                                                                       √
                                                                               (The customs form
                                                                              reference number is
                                                      10 January 2025
                                                                             required to be input in
                                                                                  the self-billed
                                                                                    e-Invoice)
                           1 January 2025
       Shipment 2                                     12 March 2025                     X
b) If the foreign supplier’s invoice is issued after the first RMCD’s clearance
   •     The Malaysian buyer is required to issue:
         •   self-billed e-Invoice for each import shipment, based on the amount declared to
             RMCD. The self-billed e-Invoice is required to be issued as per the timing of issuance
             outlined under Section 10.4.8 of the e-Invoice Specific Guideline (i.e., latest by the end
             of the second month following the month of each RMCD’s clearance is obtained) and
                                                 22
             the relevant customs form reference number (e.g., Customs Form No. 1) is required
             to be input in each self-billed e-Invoice; and
         •   a final self-billed e-Invoice upon issuance of the foreign supplier’s invoice. The final
             self-billed e-Invoice is required to be issued by the next RMCD’s clearance (timing of
             issuance is outlined under Section 10.4.8 of the e-Invoice Specific Guideline i.e., latest
             by the end of the second month following the month of RMCD’s clearance is obtained)
             and the relevant customs form reference number (e.g., Customs Form No. 1) is
             required to be input in the said self-billed e-Invoice.
   •     No self-billed e-Invoice is required to be issued for the subsequent shipments of goods
         that are included within the same foreign supplier’s invoice.
   •     As an example, Company ABC Sdn Bhd has purchased 4,000 units of machinery from
         DEF Ltd in China. The machineries will be imported into Malaysia via four separate
         shipments. The issuance of self-billed e-Invoice shall be as follows:
c) If the foreign supplier’s invoice is issued after the final import shipment
   •     The Malaysian buyer is required to issue:
         •   self-billed e-Invoice for each import shipment, based on the amount declared to
             RMCD. The self-billed e-Invoice is required to be issued as per the timing of issuance
             outlined under Section 10.4.8 of the e-Invoice Specific Guideline (i.e., latest by the end
             of the second month following the month of each RMCD’s clearance is obtained) and
             the relevant customs form reference number (e.g., Customs Form No. 1) is required
             to be input in each self-billed e-Invoice; and
         •   a final self-billed e-Invoice upon the issuance of foreign supplier’s invoice, if the total
             amount in the foreign supplier’s invoice is different from the total self-billed e-Invoices.
             The final self-billed e-Invoice is required to be issued latest by the end of the second
             month following the month of the foreign supplier’s invoice.
   •     As an example, Company ABC Sdn Bhd has purchased 4,000 units of machinery from
         DEF Ltd in China. The machineries will be imported into Malaysia via four separate
         shipments. The issuance of self-billed e-Invoice shall be as follows:
                                                  23
                       Date of foreign           Date of RMCD’s
     Shipment                                                          Self-billed e-Invoice
                      supplier’s invoice            clearance
73. If I purchase goods from foreign supplier but the goods are delivered from a bonded
    warehouse / Free Zone, do I need to include the customs form reference number in the self-
    billed e-Invoice issued?
Where the goods are delivered by the Foreign Supplier from the bonded warehouse / Free Zone
to the Malaysian buyer located in a PCA, the Malaysian buyer is required to input the customs
form reference number (e.g., Customs Form No. 1 or No. 9) in the self-billed e-Invoice. Kindly
refer to the illustration below for further clarity.
                                            24
74. If I am located in a bonded warehouse and purchase goods from a foreign supplier, and the
    said goods are subsequently sold to a Malaysian buyer, what are the e-Invoice treatments?
In a scenario where Malaysian Buyer #1 located in a bonded warehouse purchases goods from
a Foreign Supplier and subsequently sell the goods to Malaysian Buyer #2, the e-Invoice
treatments are as follows:
a) Malaysian Buyer #1 to issue a self-billed e-Invoice for the goods purchased from the Foreign
   Supplier. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. As such,
   the Malaysian Buyer #1 may input the customs form reference number (e.g., Customs Form
   No. 8) at their discretion. Kindly refer to Step 4 of the illustration below for further clarity.
b) Malaysian Buyer #1 to issue an e-Invoice for the goods sold to Malaysian Buyer #2. The
   “Reference Number of Customs Form No. 1, 9, etc.” field is optional. Kindly refer to Step 8 of
   the illustration below for further clarity.
75. If I purchase goods from a foreign supplier (where the goods are stored in bonded warehouse
    / Free Zone) and I subsequently sell the goods to another Malaysian buyer (i.e., MY Buyer
    #2), how should the e-Invoice and self-billed e-Invoice be issued?
In a scenario where Malaysia Buyer #1 purchases goods from a Foreign Supplier who stores the
goods in bonded warehouse / Free Zone and Malaysian Buyer #1 subsequently sells the said
goods to Malaysian Buyer #2, the e-Invoice treatments are as follows:
a) Malaysian Buyer #1 to issue a self-billed e-Invoice for the goods purchased from the Foreign
   Supplier. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. As such,
   the Malaysian Buyer #1 may input the customs form reference number (e.g., Customs Form
   No. 8) at their discretion. Kindly refer to Step 5 of the illustration below for further clarity.
                                               25
b) Malaysian Buyer #1 to issue an e-Invoice for the goods sold to Malaysian Buyer #2. The
   “Reference Number of Customs Form No.1, 9, etc.” field is optional. Kindly refer to Step 9 of
   the illustration below for further clarity.
76. I purchase goods from a foreign supplier and subsequently sell the goods to other Malaysian
    buyers. However, I instruct the foreign supplier to directly deliver the goods to the other
    Malaysian buyers. How should the e-Invoice and self-billed e-Invoice be issued?
In a situation where the goods are directly drop ship from the Foreign Supplier to the other
Malaysian buyers (e.g., Malaysian Buyer #2, #3 and #4), the e-Invoice treatments are as follows:
a) Malaysian Buyer #1 to issue a self-billed e-Invoice for the goods purchased from Foreign
   Supplier. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. Kindly
   refer to Step 3 of the illustration below for further clarity.
b) Malaysian Buyer #1 to issue e-Invoice to the other Malaysian Buyers #2, #3 and #4 for the
   goods sold respectively. The “Reference Number of Customs Form No. 1, 9, etc.” field is
   optional. Kindly refer to Step 6 of the illustration below for further clarity.
                                             26
77. Where the goods are purchased from a Malaysian supplier, whom sources the goods from a
    foreign supplier and requests for the goods to be directly delivered directly to its customers,
    how should the e-Invoice and self-billed e-Invoice be issued?
In the above scenario where the goods are directly drop ship to Malaysian Buyer #2, the e-Invoice
treatments are as follows:
a) Malaysian Buyer #1 to issue a self-billed e-Invoice for the goods purchased from the Foreign
   Supplier. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. As such,
   the Malaysian Buyer #1 may input the customs form reference number (e.g., Customs Form
   No. 8) at their discretion. Kindly refer to Step 5 of the illustration below for further clarity.
b) Malaysian Buyer #1 to issue an e-Invoice for the goods sold to Malaysian Buyer #2. The
   “Reference Number of Customs Form No. 1, 9, etc.” field is optional. Kindly refer to Step 8 of
   the illustration below for further clarity.
                                               27
78. If I purchase goods from a foreign supplier but the foreign supplier requested for the goods to
    be directly delivered from their Malaysian supplier (located in a bonded warehouse / Free
    Zone) to me, am I required to input the customs form reference number?
In a scenario where the Malaysian Buyer purchases goods from a Foreign Supplier but the goods
are directly delivered by the Foreign Supplier’s supplier in Malaysia (located in a bonded
warehouse / Free Zone) to Malaysian Buyer, the e-Invoice treatments are as follows:
a) Malaysian Buyer to issue a self-billed e-Invoice for the goods purchased from the Foreign
   Supplier. The Malaysian Buyer is required to input the customs form reference number (e.g.,
   Customs Form No. 9) under the “Reference Number of Customs Form No. 1, 9, etc.” field
   when issuing self-billed e-Invoice. Kindly refer to Step 10 of the illustration below for further
   clarity.
b) Malaysian Supplier to issue an e-Invoice for the goods sold to the Foreign Supplier. The
   “Reference Number of Customs Form No. 2” is an optional field. Kindly refer to Step 4 of the
   illustration below for further clarity.
                                               28
79. In relation to acquisition of services from foreign suppliers, when will the Malaysian buyers be
    required to issue a self-billed e-Invoice?
The Malaysian buyers are required to issue a self-billed e-Invoice latest by the end of the month
following the month upon:
1. payment made by the Malaysian buyer; or
2. receipt of invoice from foreign supplier,
whichever is earlier.
The determination of (1) and (2) above is in accordance with the prevailing rules applicable for
imported taxable service administered by RMCD.
80. In relation to exportation of goods to foreign buyers, when will the Malaysian supplier be
    required to issue an e-Invoice?
The Malaysian suppliers are required to issue an e-Invoice as per their current invoicing
arrangement. If the customs form (e.g., Customs Form No. 2) is available, the Malaysian suppliers
may include the customs form reference number (e.g., Customs Form No. 2) in the e-Invoice.
Kindly note that this field is currently an optional field.
81. In relation to drop shipment transactions where the goods are not physically imported into
    Malaysia, when will the Malaysian taxpayers be required to issue self-billed e-Invoice?
                                               29
82. For low value goods that are declared under the electronic Pre-Alert Manifest (e-PAM) system,
    what should be input under “Reference Number of Customs Form No. 1, 9, etc.” field?
Further to harmonisation with RMCD, IRBM provides a concession allowing taxpayers to not
include the e-PAM reference number under the “Reference Number of Customs Form No. 1, 9,
etc.” field and exclude such field when issuing self-billed e-Invoice.
The following example is provided for ease of understanding.
Malaysian Buyers purchased goods from Foreign Supplier. A consolidator, who is responsible for
the delivery of the goods to the Malaysian Buyers, will obtain RMCD’s clearance on the said goods
purchased by the Malaysian Buyers in a single declaration.
In this regard, the Malaysian Buyers are required to issue self-billed e-Invoice to the to the Foreign
Supplier upon receipt of Foreign Supplier’s invoice to record its purchase. The “Reference
Number of Customs Form No.1, 9, etc.” field is optional when issuing self-billed e-Invoices. Kindly
refer to the illustration below for further clarity.
83. For goods imported via loose container load (LCL) shipment, what should be input under
    “Reference Number of Customs Form No. 1, 9, etc.” field?
Further to harmonisation with RMCD, IRBM provides a concession allowing taxpayers who import
goods via LCL shipment to exclude the “Reference Number of Customs Form No. 1, 9, etc.” when
issuing self-billed e-Invoice.
For arrangement similar to e-PAM, kindly refer to the illustration in the e-PAM FAQ above.
                                                30
84. In drop shipment transactions where the goods are not imported into Malaysia, what should
    be input under “Reference Number of Customs Form No. 1, 9, etc.” field?
As the goods are not imported into Malaysia, the “Reference Number of Customs Form No. 1, 9,
etc.” will not be applicable and taxpayers may exclude such field when issuing
e-Invoice / self-billed e-Invoice for IRBM’s validation.
85. For goods purchased under Delivered Duty Paid (DDP) incoterm, do I need to input customs
    form reference number in the “Reference Number of Customs Form No. 1, 9, etc.” field?
Further to harmonisation with RMCD, the current legislation requires the Malaysian Buyers to
retain the relevant import documentation, even if the goods are purchased under DDP incoterm.
As such, the Malaysian Buyer is required to obtain the relevant customs form reference number
from the respective foreign supplier or third-party (e.g., agent, freight forwarder, etc.) for self-billed
e-Invoice purposes.
86. If there are more than one (1) customs form reference number for the imported goods, how
    should taxpayers fill up the field of “Reference Number of Customs Form No. 1, 9, etc.”?
The format allows the taxpayers to include multiple customs form reference number, where
applicable, under the “Reference Number of Customs Form No. 1, 9, etc.” field. Refer to
e-Invoice SDK Microsite for more details.
87. Will the customs form reference number for transportation of goods between Peninsular
    Malaysia, Wilayah Persekutuan Labuan, Sabah and Sarawak be included in the
    e-Invoice?
No, taxpayers are not required to include the customs form reference number in the “Reference
Number of Customs Form No. 1, 9, etc.” for the purposes of e-Invoice.
                                                  31
PART 3: E-INVOICE FOR MSME
All persons conducting a business are required to implement e-Invoice in accordance with
their respective implementation timeline as outlined under section 1.5 of the e-Invoice
Guideline.
However, the Government of Malaysia has exempted taxpayers with annual turnover or
revenue below RM500,000 from the issuance of e-Invoice.
The following example is provided for ease of understanding:
Amzah operates a sole proprietorship, AMZ Enterprise. As at 31 December 2024, his business
recorded total annual turnover or revenue of below RM500,000. Since his business is still
below the threshold, Amzah is exempted from issuing e-Invoice (including issuance of self-
billed e-Invoice).
90. When will MSMEs be required to implement e-Invoice if their annual turnover or revenue
    have reached or exceeded the threshold of RM500,000?
MSME is required to implement e-Invoice starting from 1 January in the second year following
the YA in which the total annual turnover or revenue reaches RM500,000.
The following example is provided for ease of understanding:
                                             32
Johan operates a business specialising in the sale of fertilisers, Winner Fertilizer Sdn. Bhd.
and its accounting period ends every 31 December. As at 31 August 2026, his company
already recorded an annual turnover or revenue exceeding RM500,000. Since the company
has exceeded the exemption threshold, Winner Fertilizer Sdn. Bhd. is required to implement
e-Invoice starting from 1 January 2028, which is from 1 January in the second year after the
YA in which the exemption threshold has been surpassed.
91. What are the determination for the implementation of e-Invoice for MSMEs?
92. For sole proprietorship, how will the mandatory implementation be determined if a sole
    proprietor has more than one business?
For sole proprietorship, the determination of annual turnover or revenue below RM500,000
threshold includes all sole proprietorship businesses owned or registered under the name of
the respective sole proprietor.
The following example is provided for ease of understanding:
Awiyah owns several sole proprietorship businesses, namely RAM Cosmetic Enterprise,
Princess Tailor and Fifty Cafe. The total annual turnover or revenue as of 31 December 2026
are as follows:
                                              33
In view that the total annual turnover or revenue as of 31 December 2026 for all sole
proprietorship businesses owned or registered under Awiyah’s name exceed RM500,000,
Awiyah is required to implement e-Invoice starting from 1 January 2028.
93. Will MSMEs that have been mandated to implement e-Invoice be eligible for the exemption
    again if their annual turnover or revenue falls below the RM500,000 threshold in the
    subsequent years?
No exemption will be granted after the mandatory implementation year has been determined,
and taxpayers are required to continue issuing e-Invoices even if their total annual turnover
or revenue do not exceed RM500,000 in the subsequent years.
The following example is provided for ease of understanding:
Similar facts pattern as Winner Fertilizer Sdn. Bhd. above. However, the annual turnover or
revenue recorded as of 31 December 2027 has fallen below the RM500,000 threshold. Even
though the 2027’s annual turnover or revenue recorded is below the exemption threshold,
Winner Fertilizer Sdn. Bhd. will remain obligated to implement e-Invoice. This is due to the
requirement that no e-Invoice exemption will be provided once MSMEs have been mandated
to implement e-Invoice.
94. For eligible taxpayers that are exempted from issuance of e-Invoice, are they required to
    issue consolidated e-Invoice and self-billed e-Invoice?
Eligible taxpayers who are exempted from the issuance of e-Invoice in accordance with
section 1.6.1 of the e-Invoice Guideline are not required to issue consolidated e-Invoice and
self-billed e-Invoice.
However, IRBM would encourage the exempted taxpayers to adopt e-Invoice on a voluntary
basis.
95. If MSME has an annual turnover or revenue below RM500,000 and sells goods on a local
    e-commerce platform, is the MSME obligated to provide details to the e-commerce
    platform for issuance of e-Invoice?
Yes. This is because the obligation to issue e-Invoice / self-billed e-Invoice rests with the
e-commerce platform provider, for all transactions conducted on the e-commerce platform.
96. Can large enterprises compel MSMEs to issue e-Invoice prior to the MSMEs’ mandatory
    implementation timeline (i.e., 1 January 2026 or 1 July 2026, as the case may be)?
For clarity, the compliance obligation is from the issuance of e-Invoice perspective. In other
words, taxpayers who are within the annual turnover or revenue threshold specified in section
1.5 of the e-Invoice Guideline are required to issue and submit e-Invoice for IRBM’s validation
according to the stipulated implementation timeline.
Taxpayers who have yet to reach the mandatory implementation timeline are allowed to
continue issuing existing documentation to record transactions. Hence, taxpayers who have
                                              34
already implemented e-Invoice cannot compel other taxpayers who have not reached their
respective mandatory implementation timeline to issue an e-Invoice.
97. Are MSMEs allowed to issue consolidated e-Invoice on a monthly basis to record all
    transactions within the month?
Yes, MSMEs are allowed to issue consolidated e-Invoice to record all transactions conducted
in the previous month, except for activities / transactions stipulated under section 3.7 of the
e-Invoice Specific Guideline.
98. How can MSMEs issue consolidated e-Invoice if they currently do not issue receipts for
    their transactions?
MSMEs with annual gross takings exceeding RM150,000 for goods sold or for services
performed are required to issue serially numbered receipts for all transactions as per section
82(1)(b) of the Income Tax Act 1967. These MSMEs are then required to include the receipt
reference number in the consolidated e-Invoice issued for IRBM’s validation.
MSMEs below the abovementioned threshold are not required to issue receipts and are not
required to issue consolidated e-Invoice to IRBM.
99. If MSME conduct sales through physical store as well as e-commerce platform, must
    MSME issue e-Invoices for transactions from both sources?
MSME is required to issue e-Invoices for sales conducted through physical store.
As for the sales conducted through e-commerce platform, MSME is not required to issue any
e-Invoice as the obligation to issue e-Invoice / self-billed e-Invoice rests with the e-commerce
platform provider.
100. What support is available for MSMEs which do not have budget for new digital system
   to implement e-Invoice?
IRBM will provide support to MSMEs in complying with the e-Invoicing requirements via the
MyInvois Portal and MyInvois Mobile App which will be made available to the public for free.
101. Can MSMEs issue e-Invoice before their respective implementation timeline?
If MSMEs are ready to implement e-Invoice in advance of their implementation timeline, they
are welcome to implement earlier than the set timeline.
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PART 4: E-INVOICE TREATMENT DURING INTERIM RELAXATION PERIOD
102. Is the e-Invoice treatment during interim relaxation period applicable to taxpayers with
     mandatory implementation date on 1 January 2025, 1 July 2025 and 1 January 2026?
Yes, the 6-month interim relaxation period is applicable for all phases of e-Invoice
implementation, as follows:
 Taxpayers with an annual turnover or revenue of more than RM5             1 July 2025 to
 million and up to RM25 million                                          31 December 2025
 Taxpayers with an annual turnover or revenue of more than RM1            1 January 2026 to
 million and up to RM5 million                                              30 June 2026
103. Following the release of Income Tax (Issuance of Electronic Invoice) Rules 2024 [P.U.
     (A) 265], is the 6-month interim relaxation period for taxpayers with annual turnover or
     revenue of more than RM100 million now starting on 1 October 2024, instead of the
     previously stated 1 August 2024?
No, the commencement of the 6-month interim relaxation period for taxpayers with an annual
turnover or revenue of more than RM100 million remains unchanged, i.e., from 1 August 2024.
This interim relaxation period applies to all phases of e-Invoice implementation as stated in
Section 16 of the e-Invoice Specific Guideline and in the immediate preceding question above.
104. Are all taxpayers required to adopt the e-Invoice treatment during the interim relaxation
     period, or do they have the option to issue individual e-Invoices and individual self-billed
     e-Invoices in accordance with the current requirements outlined in the e-Invoice
     Guideline and Specific Guideline if their system is ready?
Please note that the e-Invoice treatment during interim relaxation period is provided for
taxpayers who have yet to be ready to issue individual e-Invoices and individual self-billed
e-Invoices in accordance with the current requirements outlined in the e-Invoice Guideline and
Specific Guideline.
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If a taxpayer’s system is ready to issue individual e-Invoices / individual self-billed e-Invoices
for each transaction, the taxpayer may opt to not adopt the e-Invoice treatment during interim
relaxation period and issue individual e-Invoices and individual self-billed e-Invoices as per
the requirements outlined in the e-Invoice Guideline and Specific Guideline.
105. During the interim relaxation period, are taxpayers obligated to issue and submit
     consolidated e-Invoices / consolidated self-billed e-Invoices for IRBM’s validation on a
     monthly basis or only once at the end of the 6-month period?
Taxpayers are still required to issue the consolidated e-Invoices / consolidated self-billed
e-Invoices on a monthly basis, in accordance with the timing of issuance of consolidated
e-Invoice and consolidated self-billed e-Invoice as stipulated under sections 3.6.2 and 3.6.6
of the e-Invoice Specific Guideline respectively.
106. Are taxpayers required to issue individual self-billed e-Invoice / consolidated self-billed
     e-Invoice for importation of goods if the customs clearance is obtained prior to mandatory
     implementation date (e.g., prior to 1 August 2024 for phase 1 taxpayers)?
Where the customs clearance of the imported goods is obtained before the mandatory
implementation date, there would not be any requirement to issue self-billed e-Invoice for the
said imported goods.
107. During the interim relaxation period, when should the phase 1 taxpayers issue individual
     self-billed e-Invoice / consolidated self-billed e-Invoice for importation of goods, if the
     customs clearance is obtained in the month of August 2024?
Where the customs clearance of the imported goods is obtained in the month of August 2024,
the timing of issuance of self-billed e-Invoice are as follows:
(i)    Individual self-billed e-Invoice: Latest by 31 October 2024, in accordance with section
       10.4.8 of the e-Invoice Specific Guideline
(ii)   Consolidated self-billed e-Invoice: Latest by 7 November 2024, in accordance with
       section 3.6.6 of the e-Invoice Specific Guideline
108. Are taxpayers required to issue individual self-billed e-Invoice / consolidated self-billed
     e-Invoice for importation of services if the taxpayers have made payment for the
     imported services or if the foreign supplier’s invoice is received prior to mandatory
     implementation date (e.g., prior to 1 August 2024 for phase 1 taxpayers)?
Where the taxpayer has made payment for the imported services or if the foreign supplier’s
invoice is received before the mandatory implementation date, there would not be any
requirement to issue self-billed e-Invoice for the said imported services.
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109. During the interim relaxation period, when should the phase 1 taxpayers issue individual
     self-billed e-Invoice / consolidated self-billed e-Invoice for importation of services, upon
     (1) payment made by the taxpayer, or (2) receipt of invoice from foreign supplier,
     whichever earlier, in the month of August 2024?
If the earlier of the aforementioned events occurred in August 2024, the timing of issuance of
self-billed e-Invoice are as follows:
(i)    Individual self-billed e-Invoice: Latest by 30 September 2024, in accordance with
       section 10.4.9 of the e-Invoice Specific Guideline
(ii)   Consolidated self-billed e-Invoice: Latest by 7 October 2024, in accordance with
       section 3.6.6 of the e-Invoice Specific Guideline
110. Are taxpayers required to share the consolidated e-Invoice / consolidated self-billed
     e-Invoice with the buyers / suppliers?
The taxpayer is not required to share validated consolidated e-Invoice with the buyers /
validated consolidated self-billed e-Invoice with the suppliers.
111. Are taxpayers required to input the receipt numbers under the “Description of Product /
     Service” field for the issuance of consolidated e-Invoice / consolidated self-billed
     e-Invoice during the interim period?
No, taxpayers are allowed to input any description as appropriate when issuing consolidated
e-Invoice / consolidated self-billed e-Invoice during the interim relaxation period.
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PART 5: SYSTEMS, DATA SECURITY AND PRIVACY
(i) Issuance of e-Invoice to MyInvois System via API and/or MyInvois Portal
 112. Can a company use a combination of transmission mechanisms (API and MyInvois
      Portal)?
113. Is there a file size limit for submission of e-Invoices to MyInvois System?
 In order to improve the performance of the MyInvois System, the following limitations have
 been put in place:
 a) maximum size of 5MB per submission;
 b) maximum of 100 e-Invoices per submission; and
 c) maximum size of 300KB per e-Invoice.
 No restrictions on the number of lines in an e-Invoice will be imposed, as long as the
 requirements above are met.
 For more information, please visit the e-Invoice SDK Microsite via the following link
 https://sdk.myinvois.hasil.gov.my/einvoicingapi/02-submit-documents/#additional-
 considerations.
114. Will IRBM provide any technical guide on system integration to the MyInvois System?
115. Can taxpayers adopt Peppol as the transmission mechanism for e-Invoice?
 Taxpayers are allowed to select any transmission method including using Peppol Service
 Providers, that is most suited to their business nature and preference. Any service providers
 in the market that can comply to IRBM’s API requirements are welcomed.
 Refer to Section 2.2 of the e-Invoice Guideline or MDEC’s official portal at https://mdec.my/
 for further details.
 For any queries regarding e-Invoicing using Peppol, kindly e-mail to clic@mdec.com.my.
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116. Is there a registration requirement for technology providers to participate in the
     implementation?
117. Do technology providers need to apply for a certification in Malaysia in order to provide
     the CTC e-Invoice solution?
Not at this juncture. However, this may change in the future. Kindly refer to IRBM’s Official
Portal for any latest updates on the latest position.
118. For taxpayers who are currently not using any system for invoicing purposes, how should
     the taxpayers adopt and implement e-Invoicing?
Taxpayers are encouraged to utilise the MyInvois Portal hosted by IRBM (which is provided
free of charge to all taxpayers).
Alternatively, taxpayers may consider engaging third-party service providers to understand on
their service offerings in facilitating taxpayers’ adoption of e-Invoice.
119. Is MyInvois Portal able to accept large volume of e-Invoices from taxpayers?
MyInvois Portal supports both individual and batch e-Invoice generation through spreadsheet
upload for processing multiple transactions.
MyInvois System will undergo testing with actual estimated volume of e-Invoices before its
go-live. Additionally, it is designed to scale up additional computing resources as and when
required.
120. Is there any specific application required to scan the QR code embedded in the visual
     representation of e-Invoice generated by MyInvois portal?
Any device (e.g., mobile phone camera, QR code scanner application) capable of scanning a
QR code can be used to scan the QR code embedded in the visual representation of e-Invoice
generated by MyInvois portal.
121. What is the workaround in the event that the MyInvois System is down?
System will be available 99.97% of the time. However, in the event that IRBM’s system is
down, suppliers are given 72 hours to issue an e-Invoice once system is available. A retry
mechanism shall be implemented in supplier's system to submit the e-Invoices once the
system is available.
As for MyInvois Portal, supplier should periodically check the portal to determine if it is back
online.
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(ii) Data security and data privacy
122. Does Personal Data Protection Act 2010 govern the processing of e-Invoice?
 Section 82C(11) of the Income Tax Act 1967 has outlined that the provisions of the Personal
 Data and Protection Act 2010 shall not apply to any personal data processed for e-Invoice
 issued or transmitted to the Director General.
123. Does the API solution offer security and encryption services?
 Yes, through the necessary Network & Security monitoring tools to ensure data security and
 privacy. Additionally, the API solution will utilise industry standard encryption protocol to
 ensure information transmitted remains confidential and secure.
124. How would IRBM monitor and audit the e-Invoice data security and privacy?
 IRBM adopts a high standard of data security in managing data of taxpayers. These are the
 steps that will be taken in monitoring and auditing the e-Invoice data security and privacy:
 1. IRBM will assess the data protection needs – Before IRBM starts monitoring and auditing
    the e-Invoice data security and privacy, IRBM will identify what kind of data that IRBM
    collects, processes, stores, and shares through the e-Invoice system. By having that
    process in place, IRBM will always understand the legal and contractual obligations that
    apply to the data, such as data privacy laws or specific industry standards. From the data
    protection needs, IRBM can define the data security and privacy policies and objectives.
 2. Implementation of data protection controls – In order to protect the e-Invoice data from
    unauthorised access, modification, loss, or disclosure, IRBM will implement appropriate
    technical and organisational controls. These may include encryption, authentication,
    access control, backup, firewall, antivirus, and logging.
 3. Monitoring and auditing data protection performance and incidents – This can be done by
    benchmarking the performance against the objectives and industry best practices and
    reporting, investigating, resolving, and learning from any data breaches, errors,
    complaints, or violations that may affect the e-Invoice data.
 4. Review and improve the data protection practices – IRBM will use the results of the
    monitoring and auditing activities to identify any gaps, weaknesses, or opportunities for
    improvement in the data protection policies, controls, performance, or incidents.
125. What are the measures taken by IRBM in protecting the confidentiality of e-Invoice
     submitted to IRBM?
 IRBM will ensure that the data are always secured by complying with Dasar Keselamatan ICT
 IRBM and Surat Pekeliling Am: Garis Panduan Pengurusan Keselamatan Maklumat Melalui
 Perkomputeran Awan (Cloud Computing) Dalam Perkhidmatan Awam.
 To protect e-Invoice from unauthorised access, modification, loss, or disclosure, IRBM will
 comply to industry standards and implement appropriate cybersecurity measures including
 encryption, authentication, access controls, firewalls, and more.
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Additionally, IRBM will ensure that the system is in compliance and certified with ISO/IEC
27001 Information Security Management System (ISMS) and ISO 22301 Business Continuity
Management System (BCMS).
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