FAQ
Check out all the frequent ask questions as below
01 FAQ | General FAQs
Q: Is e-Invoice applicable to transactions in Malaysia only?
E-Invoice is not limited to Malaysia only. It is also applicable for cross border transactions.
Q: Will there be any engagement sessions with IRBM?
IRBM is actively conducting a series of engagement sessions to provide comprehensive information regarding implementation of e-Invoice in Malaysia including:
-> Sharing the planning of action plans, strategies, and status developments regarding the implementation of e-Invoice.
-> Obtaining feedback and views through 2-ways communication between IRBM and taxpayers on the implementation of e-Invoice.
Q: What is the transmission mechanism to transmit e-Invoices?
- IRBM has provided 2 e-Invoice transmission: Through MyInvois Protal provided by IRBM
- Through API
- For any queries regarding the e-Invoice implementation in Malaysia, kindly send an e-mail tomyinvois@hasil.gov.my
*Note: The e-Invoice model in Malaysia adopts the Continuous Transaction Control (CTC) model. which enables a high level of control through the validation of e-Invoices received by IRBM.
Q: What are the thresholds for e-Invoice implementation to be applicable to taxpayers?
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 FY22 Audited Financial Statements.
Q: Are all industries included in the e-Invoice implementation? Are there any industries exempted?
- Currently, there are no indstries are exempted from the e-Invoice implementation.
- Note that certain persons and types of income & expenses are exempted from e-Invoice implementation.
Q: Will all business be required to issue e-Invoice?
ALL BUSINESSES will be required to issue e-Invoice in accordance to the phased mandatory implementation timeline.
Q: Is there any adjustment window allowed the supplier to cancel an invoice submitted to IRBM?
There is a 72-hours timeframe for the e-Invoice to be cancelled by the supplier.
Q: How can taxpayers start preparing for the e-Invoice implementation?
When implementing e-Invoice, there are 3 primary factors need to be considered:Human Resources: Businesses are advised to assemble a dedicated team equipped with the necessary expertise and capabilities to prepare for the implementation.
Q: How can taxpayers start preparing for the e-Invoice implementation?
- Business Processes: Conduct a comprehensive review of the current process and procedures in issuing invoice transaction documents.
- Technology & 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.
Q: What are the consequences for failure to issue e-Invoice?
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 RM 200 and not more than RM 20,000 or imprisonment not exceeding 6 months or both,for each non-compliance.
Q: 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 RM 50,000 for each year of assessment given on environmental, social & governance related expenditure, include consultation fee for the implementation of e-Invoice incurred by MSMEs, effective from year of assessment 2024 to 2027
02 FAQ | Scope and Process FAQs
Q: How do taxpayers issue an e-Invoice to a non-Tax Identification Number (TIN) holder such as foreign 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.
Q: Should taxpayers register with Companies Commission of Malaysia (SSM) input both 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-digits) for the purposes of e-Invoice issuance.
- Taxpayers in Sabah and Sarawak are required to input the business registration number provided by local authority.
Q: Which TIN should individual taxpayers use for the purposes of e-Ivnoice?
For purposes of e-Invoice, individual taxpayers should provide TIN with prefix of “IG”
Q: How long does it take for an e-Invoice to be validated by IRBM
The e-Invoice validation by IRBM will be done in near real-time.
Q: Do businesses need to submit 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 important of goods/ services and e-Invoice for foreign income.
Q: What is the timeframe to issue e-Invoice adjustments after the 72-hours validation period?
- There is no timeframe restriction for suppliers to issue e-Invoice adjustment. 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.
Q: Which types of income fall into the scope of e-Invoice?
- e-Invoice is required for all types of income and expenses, excluding certain types as outlined in the e-Invoice Genereal and Specific Guideline.
- Kindly note that above mentioned exemptions are subject to periodic reviews and updates.
Q: Prior to full implementation, there may be suppliers who do not issuee-Invoice as not reached the mandatory implementation phase/ date. In this situation, will IRBM accept normal invoices issued by these suppliers?
During the transitional period, all taxpayers will be allowed to provide either normal bill/receipt/ invoice or validated e-Invoice to substantiate a transaction for tax purpose until full implementation and e-Invoicing legislations have been enforced.
Q: 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 the e-Invoice Specific Guideline.
- Businesses who are facing poor internet connectivity and lack infrastructure to issue e-Invoice are advised to approach nearest IRBM branch located across all states in Malaysia for further discussions.
Q: Does the MyInvois Portal allow for e-Invoice to be created and stored in draft form prior to finalistion and issuance?
The supplier will be able to create e-Invoice in draft or proforma. e-Invoice will only be accepted once the validation is successful.
Q:Does the MyInvois Portal allow for editing of information after the e-Invoice has been verified by IRBM?
The supplier would need to cancel the e-Invoice within 72 hours from time of validation and reissue a new e-Invoice. 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 and refund note) to adjust the original e-Invoice issued. Thereafter, a new e-Invoice would be required to be issued accordingly.
Q: What does IRBM validate in the e-Invoice?
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.
Q: Will the supplier’s invoice number remain in the invoice document or 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 supplier will receive a validated e-Invoice, together with date and time of validation, validation link and a Unique Identifier Number assigned by IRBM.
Q: What is the e-Invoice treatment for deposits?
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.
Q: What is the e-Invoice treatment for director fees?
- 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 a contract of service, the fees are considered as part of employment income. Currently, this is being exempted from issuance of e-Invoice. Kindly note that the exemptions are subject to periodic reviews and updates.
Q: Is an e-Invoice required for disbursements and reimbursements?
An e-Invoice may be required for disbursements and reimbursements, subject to the situation.
Q: Is an e-Invoice required for return of monies to buyers?
A refund note is required for return of monies to buyers, with the following exception:
- Payment made wrongly by buyers
- Overpayment by buyers
Q: For the purposes of issuing self-billed e-Invoices, can the Malaysian buyer consolidate all invoices received from the same foreign supplier?
At this juncture, a separate self-billed e-Invoice must be issued for each individual transaction.
Q: 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 once Royal Malaysian Customs Department’s (RMCD) clearance is obtained on the imported goods. The buyers would have to include the appropriate details as listed in the e-Invoice annexure on importation of goods.
The Malaysian buyers are required to issue a self-billed e-Invoice upon:
1. Payment made by the Malaysian buyer
2. Receipt of invoice from foreign supplier whichever is earlier.
Q: Do we need to issue e-Invoice for intercompany charges?
An e-Invoice is required to be issued for intercompany charges.
Q: Is e-Invoice required for inter-department / inter-division transactions within the same company?
e-Invoice is required. However, businesses may issue e-Invoice betweem inter-department / inter-division,depending on the businesses’s practices.
Q: Is an individual landlord required to issue e-Invoice to the tenant for rental of property?
- Where the individual landord is conducting a business, an e-Invoice is required to be issued to the tenant.
- Where the individual landlord is not conducting a business, the tenant would be required to issue a self-billed e-Invoice for the rental of property.
Q: In relation to importation of goods, are taxpayers required to provide a copy of e-Invoice to JKDM for customs clearance?
In relation to importation and exportation of goods, the current process adopted by JKDM is applicable upon the implementation of e-Invoice. Any changes will be communicated by JKDM.
Q: Does e-Invoice comply with Royal Malaysian Department (RMCD) documents for RMCD clearance?
- 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
Q: Is there a registration requirement for technology providers to participate in the implementation?
- There is no registration requirement at this juncture.
- However, technology providers are responsible to ensure the functionality and reliability of their API integration with IRBM.
Q: Do technology prociders 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.
03 FAQ | System, Data Security and Privacy FAQs
Q: Does Personal Data Protection Act 2010 govern the processing of e-Invoice?
Finance (No. 2) Act 2023 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.
Q: Does the API solution offer security and encryption services?Through the necessary Network & Security monitoring tools to ensure data security and privacy. Addtionally, the API solutionn will utilise industry standard encryption protocol to ensure information transmitted remains confidential and secure.
Q: 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:
- IRBM will assess the data protection needs
- Implementation of data protection controls
- Monitoring and auditing data protection performance and incidents
- Review and improve the data protection practices
Q: Is there any specific application required to scan the QR code?The QR code will only contain a link to the validated e-Invoice. Hence, any device capable of scanning a QR code will be able to scan the QR code.
Q: 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 LHDNM and Surat Pekeliling Am: Garis Panduan Pengurusan 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.
Q: What are the measures taken by IRBM in protecting the confidentiality of e-Invoice submitted to IRBM?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).
Q: What is the file format sent to IRBM for validation purposes?Supplier must generate e-Invoice in XML or JSON file format to IRBM for validation purposes.
Q: Can a company use a combination of transmission mechanisms (API and My Invois Portal?Taxpayers are recommended to perform reconciliation to ensure no duplication of e-Invoice submitted to IRBM.
Q: What is the workaround in the event that the MyInvois System is down?
- 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.
Q: Can taxpayers adopt Peppol as the transmission mechanism for e-Invoice?Taxpayers are allowed to select any transmission method including using the 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.
Q: 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