FAQ's
- General
- Telecommunication
- Petroleum Operations
- Healthcare
- Ecommerce
- Construction
- Takaful
- Aviation
- Tourism
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Financial Services, Stockbroking
and Unit Trust
Part 1: General Frequently Asked Questions
Is e-Invoice applicable to transactions in Malaysia only?
Indeed, e-Invoice issuance isn’t confined solely to transactions within Malaysia; it also extends to cross-border transactions.
Are there plans for engagement sessions with IRBM?
IRBM is currently organizing a series of engagement sessions with industry players, tax practitioners, professional bodies, and stakeholders to offer comprehensive information regarding e-Invoice implementation in Malaysia. These sessions will involve sharing action plans, strategies, and status updates on e-Invoice implementation, as well as facilitating two-way communication between IRBM and taxpayers to gather feedback and perspectives.
Who should we reach out to if there are queries or concerns?
For any queries regarding the e-Invoice implementation in Malaysia, kindly send an e-mail to gautam.mahanti@myeinvois.my
What are the methods used for transmitting e-Invoices?
IRBM offers two e-Invoice transmission mechanisms:
- Utilizing the MyInvois Portal provided by IRBM.
- Leveraging the Application Programming Interface (API). Check www.myeinvois.my for more information.
It’s important to note that Malaysia’s e-Invoice model follows the Continuous Transaction Control (CTC) Model, ensuring rigorous control through the validation of e-Invoices received by IRBM.
What criteria determine the applicability of e-Invoice implementation for taxpayers?
Implementation of e-Invoice is mandatory for all taxpayers and will be rolled out in phases based on annual turnover or revenue thresholds outlined in the statement of comprehensive income in the FY22 Audited Financial Statements.
Are all sectors subject to e-Invoice implementation? Are there any exceptions for specific industries?
Presently, no industries are exempt from e-Invoice implementation. However, certain individuals and types of income and expenses may be exempt.
Does the supplier have a window for adjustments to cancel an invoice submitted to IRBM?
Indeed, suppliers are granted a 72-hour timeframe to cancel an e-Invoice.
Will every business need to issue e-Invoices?
Certainly, all businesses must adhere to the phased mandatory implementation timeline, which aligns with their annual turnover or revenue threshold, requiring them to issue e-Invoices accordingly.
Will IRBM offer any technical guidance for integrating systems with the MyInvois System?
Indeed, IRBM has released an E-Invoice Software Development Kit (SDK) on February 9, 2024. This SDK comprises resources encompassing technical functionalities, Application Programming Interfaces (APIs), and development guidelines. Designed to facilitate the integration of existing systems with the MyInvois System via API, the SDK aims to support businesses in this process.
For any e-Invoice SDK-related queries, e-mail us at Gautam.mahanti@myeinvois.my
What steps should taxpayers take to prepare for e-Invoice implementation?
In readiness for e-Invoice implementation, businesses should focus on three primary factors:
- Human resources: Formulating a dedicated team equipped with the requisite expertise and skills is recommended to prepare for implementation.
- Business processes: A thorough review of current processes and procedures in issuing invoice transaction documents is essential.
- Technology and systems: Ensuring the availability of necessary resources, data structures, and existing IT capabilities to align with e-Invoice requirements is imperative.
What are the penalties for failing to issue e-Invoices?
Non-compliance with e-Invoice issuance is deemed an offense under Section 120(1)(d) of the Income Tax Act 1967. Offenders may face fines ranging from RM200 to RM20,000, imprisonment for up to 6 months, or both, for each instance of non-compliance.
Are there any incentives available to taxpayers for adopting e-Invoices?
The Malaysian government has introduced tax incentives and grants as part of Budget 2024. These include a tax deduction of up to RM50,000 per year of assessment for environmental, social, and governance-related expenses, including consultation fees for e-Invoice implementation by MSMEs. This incentive is applicable from the year of assessment 2024 to 2027.
Part 2: Scope And Process Frequently Asked Questions
How can suppliers issue an e-Invoice to a non-Tax Identification Number (TIN) holder, such as foreign (non-Malaysian) buyers?
Suppliers must obtain the necessary details from foreign buyers for e-Invoice issuance. Regarding the TIN to be included in the e-Invoice, suppliers may utilize “EI00000000020” for foreign buyers without a TIN. For further information, please refer to Section 10.5 of the e-Invoice Specific Guideline.
Should taxpayers provide both the old and new business registration numbers registered with the Companies Commission of Malaysia (SSM) when issuing an e-Invoice?
Taxpayers registered with SSM should input the new 12-digit business registration number for e-Invoice issuance purposes. For taxpayers in Sabah and Sarawak, the business registration number provided by the local authority should be utilized.
For the purposes of e-Invoice, which TIN should individual taxpayers utilize?
Individual taxpayers should furnish a TIN with the prefix “IG” for e-Invoice purposes. Further instructions on how to retrieve and verify the TIN can be found in the e-Invoice Guideline.
How long does it typically take for an e-Invoice to undergo validation by IRBM?
The validation of e-Invoices by IRBM occurs in near real-time.
Is there a requirement for businesses to submit an e-Invoice on the same day as the transaction?
There is no specific mandate regarding the timing of e-Invoice issuance, except in certain circumstances such as consolidated e-Invoices, self-billed e-Invoices for the importation of goods/services, and e-Invoices for foreign income. Businesses should adhere to any applicable legislation in such cases.
What is the timeframe for issuing e-Invoice adjustments (debit note, credit note, and refund note) following the 72-hour validation period?
Suppliers are not bound by a specific timeframe to issue e-Invoice adjustments. Taxpayers can adhere to their respective company policies for such adjustments. Given that foreign suppliers and/or buyers typically do not utilize the MyInvois System, any e-Invoice adjustments would be made through the issuance of debit notes, credit notes, or refund notes.
Which types of income are encompassed by the e-Invoice scope, considering the diverse income sources that taxpayers may have contributing to their annual turnover (e.g., interest income, investment income, gains from investment disposal)?
e-Invoice is mandated for all types of income and expenses, except for certain exemptions outlined in both the e-Invoice General Guideline and e-Invoice Specific Guideline. It’s important to note that these exemptions are subject to periodic review and updates.
Prior to full implementation, there may be suppliers who have not yet transitioned to e-Invoice issuance due to not reaching the mandatory implementation phase/date. In such instances, will IRBM accept standard invoices from these suppliers?
During the transitional phase, all taxpayers are permitted to furnish either a standard bill/receipt/invoice (in line with current business practices) or a validated e-Invoice to substantiate a transaction for tax purposes until the complete implementation of E-Invoicing legislation.
Regarding buyers dealing with suppliers in rural areas with poor internet connectivity, is it necessary for them to issue self-billed e-Invoices to document expenses?
Please be aware that self-billed e-Invoices are permitted only for specific transactions as outlined in the E-Invoice Specific Guideline. Businesses encountering challenges with internet connectivity and lacking infrastructure to generate e-Invoices are encouraged to reach out to the nearest IRBM branch across all states in Malaysia for further consultations.
Does the MyInvois Portal support the creation and storage of e-Invoices in draft form before finalization and issuance?
Yes, suppliers have the capability to draft or create e-Invoices in a proforma format. However, the e-Invoice will only be deemed valid upon successful validation.
Is it possible to edit information on the MyInvois Portal after an e-Invoice has been validated by IRBM?
No, it is not possible. Suppliers must cancel the e-Invoice within 72 hours from the time of validation and subsequently issue a new e-Invoice if any alterations are needed. Any modifications made after the 72-hour validation period necessitate the issuance of a new e-Invoice, such as a debit note, credit note, or refund note e-Invoice, to rectify the original one. Subsequently, a new e-Invoice must be generated accordingly.
What verification procedures does IRBM conduct on the e-Invoice?
IRBM validation encompasses a series of checks aimed at ensuring that the e-Invoice submitted to IRBM adheres to the specified e-Invoice format and data structure set by IRBM.
Will the supplier’s invoice number remain unchanged in the invoice document, or will IRBM assign a different invoice number upon the return of the validated e-Invoice to the supplier?
The supplier’s invoice number will persist as a distinct field within the same invoice document, serving the supplier’s internal reference and tracking purposes. Following validation, the supplier will receive a validated e-Invoice, inclusive of the validation date and time, a validation link, and a Unique Identifier Number assigned by IRBM.
What procedures apply to deposits in the context of e-Invoicing?
In instances where the deposit is refundable, the issuance of an e-Invoice is unnecessary. However, if the deposit is non-refundable, the issuance of an e-Invoice becomes mandatory.
How are director fees handled in the e-Invoice system?
If a director has entered into a contract for service, they must issue an e-Invoice to the company for any income received. However, if the director is under a contract of service, where the fees are considered part of employment income, they are currently exempt from e-Invoice issuance according to the e-Invoice Guideline. It’s important to note that these exemptions are subject to periodic review and updates.
Is an e-Invoice necessary for disbursements and reimbursements?
The requirement for an e-Invoice for disbursements and reimbursements depends on the specific situation. Please refer to Section 5 of the e-Invoice Specific Guideline for more information.
Is an e-Invoice mandatory for returning money to buyers?
Yes, a refund note e-Invoice is required for returning money to buyers, with the following exceptions:
- Payment made in error by buyers
- Buyer overpayment
- Return of security deposits
Regarding the issuance of self-billed e-Invoices, can Malaysian buyers consolidate multiple invoices received from the same foreign supplier?
No, currently, each individual transaction requires a separate self-billed e-Invoice.
Concerning the acquisition of goods from foreign suppliers, when must Malaysian buyers issue a self-billed e-Invoice?
Malaysian buyers must issue a self-billed e-Invoice once they obtain clearance from the Royal Malaysian Customs Department (RMCD) for the imported goods. The e-Invoice must include the relevant details outlined in the annexure on the importation of goods.
In the context of acquiring services from foreign suppliers, when should Malaysian buyers issue a self-billed e-Invoice?
Malaysian buyers are required to issue a self-billed e-Invoice either upon payment by the Malaysian buyer or upon receipt of the invoice from the foreign supplier, whichever occurs earlier.
Is it necessary to generate an e-Invoice for intercompany charges?
Indeed, issuing an e-Invoice for intercompany charges is mandatory.
Regarding transactions between different departments or divisions within the same company, is an e-Invoice obligatory?
No, an e-Invoice is not compulsory for inter-department or inter-division transactions within the same company. However, businesses may choose to utilize e-Invoices for such transactions based on their internal practices.
Must an individual landlord issue an e-Invoice to tenants for property rental?
If the individual landlord is engaged in business activities, they are required to issue an e-Invoice to the tenant for property rental.
If the individual landlord is not engaged in business activities, the tenant (provided they are a business entity) would need to issue a self-billed e-Invoice for the rental of the property.
Are taxpayers obliged to furnish a copy of the e-Invoice to JKDM for customs clearance concerning importation and exportation of goods?
Regarding importation and exportation of goods, the current procedure enforced by JKDM remains applicable following the implementation of e-Invoice. Any alterations to this process will be communicated by JKDM.
Does the e-Invoice align with the documentation requirements of the Royal Malaysian Customs Department (RMCD) for RMCD clearance?
The e-Invoice specifications outlined in Appendix 1 of the e-Invoice Guideline have been crafted considering the information essential for both IRBM and RMCD. Both IRBM and RMCD may utilize the e-Invoice for tax purposes. Nevertheless, it’s important to note that the existing documentation mandated by RMCD for RMCD clearance will still be required.
Is there a prerequisite for technology providers to register in order to partake in the implementation?
As of now, there isn’t a mandatory registration requirement. Nonetheless, technology providers are accountable for ensuring the functionality and dependability of their API integration with IRBM.
Is it necessary for technology providers to seek certification in Malaysia to offer the CTC e-Invoice solution?
As of now, such a requirement is not in place. Nevertheless, it’s advisable to stay informed about potential future changes. For the latest updates on this matter, please consult IRBM’s Official Portal.
Part 3: Systems, Data Security And Privacy Frequently Asked Questions
Is the processing of e-Invoices governed by the Personal Data Protection Act 2010?
The Finance (No. 2) Act 2023 specifies that the provisions of the Personal Data Protection Act 2010 do not apply to any personal data processed for e-Invoices issued or transmitted to the Director General.
Does the API solution include security and encryption features?
Yes, the API solution incorporates essential Network & Security monitoring tools to uphold data security and privacy. Moreover, it employs industry-standard encryption protocols to safeguard the confidentiality and integrity of transmitted information.
How does IRBM oversee and audit the security and privacy of e-Invoice data?
IRBM upholds stringent data security standards in managing taxpayers’ data. The monitoring and auditing of e-Invoice data security and privacy involve the following steps:
- Assessment of data protection needs: Before commencing monitoring and auditing, IRBM identifies the types of data collected, processed, stored, and shared through the e-Invoice system. This process ensures compliance with legal and contractual obligations, such as data privacy laws and industry standards. Based on these needs, IRBM defines data security and privacy policies and objectives.
- Implementation of data protection controls: To safeguard e-Invoice data from unauthorized access, modification, loss, or disclosure, IRBM implements appropriate technical and organizational controls. These measures may include encryption, authentication, access control, backup, firewall, antivirus, and logging.
- Monitoring and auditing data protection performance and incidents: IRBM benchmarks performance against objectives and industry best practices, and reports, investigates, resolves, and learns from any data breaches, errors, complaints, or violations affecting e-Invoice data.
- Review and improvement of data protection practices: IRBM utilizes monitoring and auditing results to identify gaps, weaknesses, or improvement opportunities in data protection policies, controls, performance, or incidents.
Is there a specific application needed to scan the QR code?
The QR code will simply contain a link to the validated e-Invoice. Therefore, any device capable of scanning a QR code, such as a mobile camera or a QR code scanner application, will suffice.
What measures does IRBM take to safeguard the confidentiality of e-Invoices submitted to them?
IRBM ensures the constant security of data by adhering to the ICT Security Policy of LHDNM and the General Circular: Guidelines for Information Management through Cloud Computing in the Public Service.
To safeguard e-Invoices from unauthorized access, alteration, loss, or disclosure, IRBM adheres to industry standards and implements robust cyber security measures, including encryption, authentication, access controls, firewalls, and more.
Furthermore, IRBM ensures system compliance and certification with ISO/IEC 27001 Information Security Management System (ISMS) and ISO 22301 Business Continuity Management System (BCMS).
What is the file format used for sending e-Invoices to IRBM for validation purposes?
Suppliers are required to generate e-Invoices in either XML or JSON file format when submitting them to IRBM for validation.
Can a company utilize a combination of transmission mechanisms, such as API and the MyInvois Portal?
Yes, companies have the option to utilize both the API and the MyInvois Portal for transmitting e-Invoices. However, it’s recommended that taxpayers conduct reconciliation to prevent any duplication of e-Invoices submitted to IRBM.
What is the procedure to follow if the MyInvois System experiences downtime?
While the system is designed to be available 99.97% of the time, in the rare event of IRBM’s system downtime, suppliers are granted a 72-hour window to issue e-Invoices once the system is operational again. A retry mechanism should be incorporated into the supplier’s system to automatically submit the e-Invoices once the system is back online.
Regarding the MyInvois Portal, suppliers should periodically check its availability and proceed to submit e-Invoices once it’s accessible.
Can taxpayers opt for Peppol as the transmission mechanism for e-Invoices?
Taxpayers have the flexibility to choose any transmission method, including utilizing Peppol Service Providers, that aligns best with their business requirements and preferences. All service providers in the market that can adhere to IRBM’s API specifications are welcomed.
Is the MyInvois Portal capable of handling a large volume of e-Invoices from taxpayers?
The MyInvois Portal facilitates both individual and batch e-Invoice generation, allowing taxpayers to upload spreadsheets for processing multiple transactions. Prior to its launch, the MyInvois System undergoes rigorous testing with estimated volumes of e-Invoices to ensure seamless operation. Furthermore, it is equipped to scale up additional computing resources as needed.
Implementation Of E-Invoice In Malaysia
Frequently Asked Questions (FAQs) For Telecommunication
Will the telecommunication service providers continue their practice of reflecting adjustments from previous bills/statements in the next billing cycle to customers upon the implementation of e-Invoice, or will they need to amend their current procedures?
The telecommunication service provider is permitted to adjust the previous bill/statement through either:
- Incorporating the adjustment in the subsequent billing cycle’s bill/statement; or
- Issuing a credit note/debit note/refund note e-Invoice,
in alignment with their existing business practices.
The telecommunication service provider may vend prepaid plans to agents or trading companies, who then resell these plans to consumers. Presently, the telecommunication service provider issues invoices to agents or trading companies for the prepaid plans sold. Will this billing/invoicing arrangement persist post e-Invoice implementation, or will the telecommunication service provider need to amend its current procedures?
The telecommunication service provider may adhere to the existing billing arrangement.
Upon implementation of e-Invoice, how should the rental of premises by the telecommunication service provider be addressed in terms of e-Invoice issuance?
If the landlord is an individual or a company engaged in business activities, they must issue an e-Invoice to document the income from the rented premises. However, if the landlord is an individual not engaged in business, the telecommunication service provider must act as the issuer and generate a self-billed e-Invoice to validate the transaction for taxation purposes.
Who is responsible for issuing the e-Invoice to customers for add-on services like video streaming subscriptions, which are paid through the telecommunication service provider?
The telecommunication service provider solely facilitates the payment process for the add-on service. Regarding the issuance of e-Invoices:
- If the third-party vendor is a local entity, they are responsible for issuing the e-Invoice to the customer.
- If the third-party vendor is foreign, the customer must act as the Issuer and issue a self-billed e-Invoice for the service.
- For any platform fees or commissions earned by the telecommunication service provider, they must issue e-Invoices accordingly.
Implementation Of E-Invoice In Malaysia
Frequently Asked Questions (FAQs) For Petroleum Operations
What Tax Identification Number (TIN) should be utilized as the Supplier’s TIN, along with the corresponding Supplier’s details, when a contractor of a Production Sharing Contract (PSC) sells crude oil to a buyer?
When issuing an e-Invoice for the sale between the contractor and the buyer, the contractor’s Tax Identification Number (TIN) designated for Income Tax Act 1967 (ITA 1967) purposes should be utilized as the Supplier’s TIN. Additionally, the contractor’s details should be provided as the Supplier’s details on the e-Invoice. It’s important for contractors to include the appropriate classification coding, as specified in the e-Invoice data catalogue, in the invoice to signify that the transaction pertains to petroleum operations as defined in the Petroleum (Income Tax) Act 1967.
What TIN should be utilized as the Buyer’s TIN for expenses associated with petroleum operations?
- Joint costs
For joint costs, the PSC operator’s TIN designated for ITA 1967 purposes is utilized as the Buyer’s TIN. - Sole costs
For sole costs, the contractor’s TIN designated for ITA 1967 purposes is used as the Buyer’s TIN, as these expenses are incurred solely for the contractor.IRBM recognizes the challenges associated with issuing e-Invoices for recharging joint costs related to petroleum operations to respective PSCs. Therefore, until further notice, PSC operators and/or contractors are exempted from issuing e-Invoices for the recharge of joint costs related to petroleum operations.
What TIN should be used in the scenario where multiple PSCs are situated in the same operational area (i.e., contiguous block)?
- For the sale of crude oil, which TIN should be designated as the Supplier’s TIN?
Regarding the Supplier’s TIN: The TIN number designated to the contractor for ITA 1967 purposes is to be utilized as the Supplier’s TIN in the corresponding e-Invoice.
- For costs incurred for petroleum operations, which TIN should be designated as the Buyer’s TIN?
Concerning the Buyer’s TIN: For joint costs, the TIN assigned to the operator of the contiguous PSC for ITA 1967 purposes should serve as the Buyer’s TIN. As for sole costs incurred by contractors of contiguous PSCs, the TIN assigned to the contractor for ITA 1967 purposes should be employed as the Buyer’s TIN.
Should e-Invoice issuance be mandated for inter-ledger transactions occurring between a PSC and the operator of the PSC, such as back charges?
IRBM recognizes the potential difficulties associated with issuing e-Invoices for inter-ledger transactions involving petroleum operations between a PSC and the operator of the PSC. Consequently, e-Invoice requirements for such transactions are waived until further notice.
How should the e-Invoice arrangement be structured if contractor(s) of a PSC finalize a sale of crude oil through an agent?
The existing invoicing procedure will remain in effect with the implementation of e-Invoice. For instance, if the contractor sells the petroleum product to the agent, who then sells it to the buyer, the contractor should issue an e-Invoice to the agent, and the agent should issue an e-Invoice to the buyer.
Will the operator of the PSC be permitted to issue e-Invoices on behalf of contractors under the Upstream Gas Sales Agreement after the implementation of e-Invoice?
The PSC operator is permitted to issue e-Invoices on behalf of contractors for the sale of gas under the Upstream Gas Sales Agreement, maintaining the existing invoicing process. When issuing e-Invoices, the contractor’s information should be utilized as the Supplier’s details. It’s important to note that the e-Invoice will only be visible in the respective contractor’s MyInvois portal after validation, and it won’t be visible in the Operator’s portal.
How should supplementary payments, such as base price increases on each production anniversary, be handled in terms of e-Invoicing?
The existing invoicing process will remain in place following the implementation of e-Invoicing. Any adjustments, whether upwards or downwards, will be managed through the issuance of debit or credit note e-Invoices.
Will cash call and joint interest billing (JIB) be included in the scope of e-Invoicing?
Cash call and joint interest billing (JIB) are settlement methods and do not require the issuance of e-Invoices.
Implementation Of E-Invoice In Malaysia
Frequently Asked Questions (FAQs) For Healthcare Industry
Presently, hospitals issue invoices for medical expenses paid on behalf of staff to document the expenditure. With the introduction of e-Invoicing, will this existing arrangement persist, or will the hospital need to amend its current procedures?
The hospital is permitted to adhere to the existing billing arrangement.
Presently, in cases where: 1. A segment of expenses is covered by insurance or third-party administrator (TPA); and 2. The remaining part is covered by the patients, The hospital issues one invoice to the insurance/TPA for the covered portion and another invoice to the patient for the remaining balance. With the implementation of e-Invoice, will the hospital retain the same invoicing process, or will modifications be necessary?
The hospital is permitted to adhere to its existing billing procedures. However, following the implementation of e-Invoice, the bill must be in the form of an e-Invoice.
Typically, the hospital provides a proforma bill to the insurance company to request a Final Guarantee Letter (FGL). In light of this, when should an e-Invoice be issued and sent to IRBM for validation?
The hospital may adhere to its existing billing practices. If necessary, it can provide draft or proforma invoices to the insurance company to request an FGL. Following the finalization of the invoicing/billing arrangement, the hospital must submit the e-Invoice to IRBM for validation.
Presently, consultants bill the hospital by issuing an invoice encompassing the total professional fees for the month. Subsequently, when the hospital issues invoices to the patients, the consultant fee is already integrated into the invoice. With the introduction of e-Invoice, will this invoicing arrangement persist, or will the hospital need to adjust its current procedures?
The hospital is permitted to adhere to its existing billing procedures.
In a contract for service scenario, the hospital may engage directly with individual doctors or with a company representing the doctors. With the adoption of e-Invoice, who should be responsible for issuing the e-Invoice to the hospital?
If the contract for service is directly between the hospital and an individual doctor, the supplier’s details should reflect the individual doctor, who is then responsible for issuing the e-Invoice. If the contract for service is between the hospital and a company representing the doctors, the supplier’s details should represent the company, which is then responsible for issuing the e-Invoice.
Is it mandatory to issue an e-invoice for space rental (e.g., convenience stores, cafes) within the hospital premises?
Indeed, it is necessary to issue an e-invoice for the space rental.
In cases where parents, guardians, or other relevant parties are responsible for paying the medical expenses for their child who is below 18 years of age, their details should be used as the Buyer’s details.
For e-Invoice purposes, the Buyer’s details should correspond to those of the parent, guardian, or other relevant parties, depending on the circumstances.
How is e-Invoice handled in situations where a patient is referred to a sister company or a private hospital and discharged there?
The hospital is permitted to adhere to its existing billing procedures.
Will the hospital have the option to issue a consolidated E-Invoice to document the revenue derived from medical services rendered to individual end consumers (i.e., self-paying patients) who do not necessitate an E-Invoice?
Indeed, the hospital is permitted to issue a consolidated e-Invoice for transactions involving patients who do not necessitate an e-Invoice.
How are deposits collected upon admission to hospitals treated in e-Invoices?
If the deposit is refundable, there is no need for an e-Invoice upon its receipt. However, for non-refundable deposits, an e-Invoice must be issued. Additionally, hospitals have the option to use consolidated e-Invoices for buyers who do not need them.
How should e-Invoices be handled for transactions involving payments from multiple payors?
The hospital is permitted to adhere to its existing billing procedures.
Will consultants be required to adopt e-Invoice in Phase 1 if the hospital’s annual turnover exceeds RM100 million, considering that the hospital issues invoices to the patients?
The obligation to comply with e-Invoice requirements lies with the issuance process. Consultants and hospitals must adhere to their respective thresholds for e-Invoice implementation.
Which type of bill, either a Summary Bill or a Detailed Bill (providing a breakdown of charges), should be submitted for validation by IRBM?
For e-Invoice purposes, the hospital must issue the “Detailed Bill” as the e-Invoice, which is then submitted to IRBM for validation.
Implementation Of E-Invoice In Malaysia
Frequently Asked Questions (FAQs) For E-commerce Industry
In cases where a sale or transaction occurs between a merchant and a consumer via an e-commerce platform, which party (e.g., the e-commerce platform or the merchant) bears the responsibility of issuing the e-Invoice to the consumer?
The responsibility for issuing documents to consumers in transactions conducted through the e-commerce platform lies with the e-commerce platform provider. Specifically:
- Upon request, the e-commerce platform provider is responsible for issuing the e-Invoice to the consumer.
- If the consumer does not request an e-Invoice, the e-commerce platform provider may issue a receipt instead.
Merchants are not obligated to issue e-Invoices or receipts directly to consumers.
In cases where no e-Invoice is requested, the e-commerce platform provider is permitted to issue consolidated e-Invoices for transactions with consumers. It’s important for the e-commerce platform provider to include the appropriate classification coding in the e-Invoice to indicate that it pertains to an e-commerce transaction where the e-Invoice is issued by the platform provider to the buyer.
For further details and guidance on the general issuance of e-Invoices, please consult Sections 3.5 and 3.6 of the e-Invoice Specific Guideline.
Who is responsible for issuing the e-Invoice to document the income generated by merchants, service providers (such as logistics providers), or others from transactions conducted via an e-commerce platform?
The responsibility lies with the e-commerce platform provider to act as the issuer and generate a self-billed e-Invoice. This e-Invoice is intended to document the income earned by merchants and/or service providers from transactions conducted through the e-commerce platform. The frequency of issuing self-billed e-Invoices can align with the current issuance practices of the e-commerce platform provider.
How are charges levied by the e-commerce platform provider on merchants and/or service providers for platform usage handled in terms of e-Invoicing?
The e-commerce platform provider must generate an e-Invoice for the charges incurred by the merchant and/or service provider for platform usage. The frequency of e-Invoice issuance can align with the current practices of the e-commerce platform provider.
What Tax Identification Number (TIN) should be utilized as the Supplier’s TIN if the merchant and/or service provider is a foreign entity or individual and does not furnish a TIN?
If the foreign supplier lacks a Tax Identification Number (TIN) or fails to furnish it, the standard TIN “EI00000000030” may be employed as the Supplier’s TIN in a self-billed e-Invoice. For further instructions on issuing self-billed e-Invoices, kindly consult Section 10.4 of the e-Invoice Specific Guideline.
Will e-commerce platform provider be allowed to issue consolidated e-Invoice to record the income generated by merchant and/or service provider from e-commerce transactions?
The e-commerce platform provider is prohibited from issuing consolidated e-Invoices to document the income earned by merchants and/or service providers from transactions conducted through the e-commerce platform. Instead, the e-commerce platform provider is required to issue self-billed e-Invoices for this purpose. Please refer to the response provided in Question 2 above for additional information.
The frequency of self-billed e-Invoice issuance may align with the current frequency of issuance by the e-commerce platform.
Typically, the e-commerce platform provider initiates the disbursement of payments to the merchant and/or service provider only after the consumer confirms receipt of goods and/or services. In such cases, the e-commerce platform provider should issue an e-Invoice to record the income generated by the merchant and/or service provider from e-commerce transactions.
The e-commerce platform provider is permitted to maintain its existing billing process. If necessary, the platform provider may issue draft or proforma invoices to the merchant and/or service provider. However, only the finalized e-Invoice needs to be submitted to IRBM for validation.
How should e-Invoices be handled when the e-commerce platform provider refunds money to affected consumers due to returned goods?
The e-commerce platform provider must issue a refund note e-Invoice to document the reimbursement for returned goods.
Are retailers permitted to combine e-commerce transactions with brick-and-mortar store transactions in a single consolidated e-Invoice?
Considering that the transaction process, obligations, and categorization (outlined in the e-Invoice data catalog) may vary between e-commerce transactions and those conducted through brick-and-mortar stores, combining them into a consolidated e-Invoice might not be recommended. This approach could potentially lead to increased complexity during future reconciliation processes.
Implementation Of E-Invoice In Malaysia
Frequently Asked Questions (FAQs) For Construction Industry
In cases where a sale or transaction occurs between a merchant and a consumer via an e-commerce platform, which party (e.g., the e-commerce platform or the merchant) bears the responsibility of issuing the e-Invoice to the consumer?
The responsibility for issuing documents to consumers in transactions conducted through the e-commerce platform lies with the e-commerce platform provider. Specifically:
- Upon request, the e-commerce platform provider is responsible for issuing the e-Invoice to the consumer.
- If the consumer does not request an e-Invoice, the e-commerce platform provider may issue a receipt instead.
Merchants are not obligated to issue e-Invoices or receipts directly to consumers.
In cases where no e-Invoice is requested, the e-commerce platform provider is permitted to issue consolidated e-Invoices for transactions with consumers. It’s important for the e-commerce platform provider to include the appropriate classification coding in the e-Invoice to indicate that it pertains to an e-commerce transaction where the e-Invoice is issued by the platform provider to the buyer.
For further details and guidance on the general issuance of e-Invoices, please consult Sections 3.5 and 3.6 of the e-Invoice Specific Guideline.
Who is responsible for issuing the e-Invoice to document the income generated by merchants, service providers (such as logistics providers), or others from transactions conducted via an e-commerce platform?
The responsibility lies with the e-commerce platform provider to act as the issuer and generate a self-billed e-Invoice. This e-Invoice is intended to document the income earned by merchants and/or service providers from transactions conducted through the e-commerce platform. The frequency of issuing self-billed e-Invoices can align with the current issuance practices of the e-commerce platform provider.
How are charges levied by the e-commerce platform provider on merchants and/or service providers for platform usage handled in terms of e-Invoicing?
The e-commerce platform provider must generate an e-Invoice for the charges incurred by the merchant and/or service provider for platform usage. The frequency of e-Invoice issuance can align with the current practices of the e-commerce platform provider.
What Tax Identification Number (TIN) should be utilized as the Supplier’s TIN if the merchant and/or service provider is a foreign entity or individual and does not furnish a TIN?
If the foreign supplier lacks a Tax Identification Number (TIN) or fails to furnish it, the standard TIN “EI00000000030” may be employed as the Supplier’s TIN in a self-billed e-Invoice. For further instructions on issuing self-billed e-Invoices, kindly consult Section 10.4 of the e-Invoice Specific Guideline.
Will e-commerce platform provider be allowed to issue consolidated e-Invoice to record the income generated by merchant and/or service provider from e-commerce transactions?
The e-commerce platform provider is prohibited from issuing consolidated e-Invoices to document the income earned by merchants and/or service providers from transactions conducted through the e-commerce platform. Instead, the e-commerce platform provider is required to issue self-billed e-Invoices for this purpose. Please refer to the response provided in Question 2 above for additional information.
The frequency of self-billed e-Invoice issuance may align with the current frequency of issuance by the e-commerce platform.
Typically, the e-commerce platform provider initiates the disbursement of payments to the merchant and/or service provider only after the consumer confirms receipt of goods and/or services. In such cases, the e-commerce platform provider should issue an e-Invoice to record the income generated by the merchant and/or service provider from e-commerce transactions.
The e-commerce platform provider is permitted to maintain its existing billing process. If necessary, the platform provider may issue draft or proforma invoices to the merchant and/or service provider. However, only the finalized e-Invoice needs to be submitted to IRBM for validation.
How should e-Invoices be handled when the e-commerce platform provider refunds money to affected consumers due to returned goods?
The e-commerce platform provider must issue a refund note e-Invoice to document the reimbursement for returned goods.
Are retailers permitted to combine e-commerce transactions with brick-and-mortar store transactions in a single consolidated e-Invoice?
Considering that the transaction process, obligations, and categorization (outlined in the e-Invoice data catalog) may vary between e-commerce transactions and those conducted through brick-and-mortar stores, combining them into a consolidated e-Invoice might not be recommended. This approach could potentially lead to increased complexity during future reconciliation processes.
Implementation Of E-Invoice In Malaysia
Frequently Asked Questions (FAQs) For Insurance and Takaful Industry
A. General
Is the insurance company permitted to issue a consolidated e-Invoice for recording income from insurance policies sold to policyholders who do not require e-Invoices?
Yes, insurance companies are permitted to issue consolidated e-Invoices for transactions involving policyholders who do not require individual e-Invoices.
Can annual premium statements be utilized for consolidated e-Invoice purposes?
Yes, insurance companies are permitted to use annual premium statements for consolidated e-Invoice purposes in cases where policyholders do not require individual e-Invoices. In such cases, insurance companies will issue a normal statement or bill to the buyer, following current business practices, without submitting it for IRBM’s validation. Insurance companies can aggregate these statements or bills to create and submit a consolidated e-Invoice for IRBM’s validation, following the current issuance period for statements or bills. The submission must be made within seven (7) calendar days after the end of the month in which the statements or bills were issued.
Since the first annual premium statement will only be available in February/March 2025, covering the full year premium paid from January 2024 to December 2024, can the entire year’s data be transmitted in February/March 2025, or must the period from January to July 2024 be excluded due to the mandatory implementation date of 1 August 2024?
If the first annual premium statement is only available in February/March 2025 and covers the full year premium paid from January 2024 to December 2024, it is acceptable to transmit the entire year’s data in February/March 2025. There is no need to exclude the period from January to July 2024.
Can customers request a validated e-Invoice from the insurance company at times other than the annual premium statement issuance?
The process for issuing e-Invoices should be adhered to as per current procedures. Insurance companies must clearly communicate with customers and guide them on how to request validated e-Invoices within the established framework, such as during the regular premium statement issuance cycle.
Can individual policyholders request an e-Invoice for products that are not eligible for tax relief?
As a general rule, the term “Buyer” for e-Invoicing purposes refers to the policyholder. When the buyer requests an e-Invoice, the insurance company is obligated to issue one.
B. Underwriting and distribution
Once e-Invoicing is implemented, will the insurance company be required to provide a detailed breakdown of the premium paid for insurance policies in the e-Invoice?
Yes, for e-Invoicing purposes, the insurance company will need to provide a detailed breakdown of the premiums paid for the insurance policies in the e-Invoice (e.g., Life, Medical, Others) and include the appropriate classification codes, such as:
– 014: Insurance – Education and medical benefits
– 015: Insurance – Takaful or life insurance
– 022: Others
– 024: Private retirement scheme or deferred annuity scheme
Whose details should be used as the Buyer’s information for a joint insurance policy (e.g., fire insurance) that covers two policyholders under a single policy?
The current process can be maintained with one e-Invoice issued for each insurance policy. For joint policyholders, the principal policyholder who receives the invoice from the insurance company should be listed as the Buyer on the e-Invoice. However, if the other policyholder requests an e-Invoice, the insurance company must issue a separate e-Invoice to that policyholder.
Currently, the insurance company includes collections on behalf of others (e.g., stamp duty, third-party fees, etc.) in the policyholder’s invoice, along with the premium. With the implementation of e-Invoicing, will this practice continue, or will the insurance company need to modify its current procedures?
If the e-Invoice for the collection on behalf is to be issued to the insurance company, it must include the collection on behalf. It is important to note that such collections will not be recognized as the insurance company’s income, and the appropriate classification code should be selected by the insurance company. However, if the e-Invoice for the collection on behalf is to be issued directly to the policyholder, the insurance company is not required to include the collection on behalf in their e-Invoice.
Generally, the sale of insurance products and/or services through intermediaries is conducted in two ways:
Scenario 1: Master policy between the insurance company and intermediary, with end customers as insured persons.
Currently, the intermediary issues an invoice/receipt that records the premium received from the policyholder (i.e., end customers). Consequently, the insurance company issues another invoice to the intermediary for the premium received. Insurance companies may directly deliver the cover note/insurance policy to the customers as insured persons, while the intermediary is listed as the master policyholder.
Scenario 2: Individual policy between the insurance company and the end customer is established. Insurance companies issue individual policies directly to end customers, whether the customers purchased the policy through intermediaries.
In this context, to whom should the e-Invoice be issued?
Here is a rephrased version:
In the specified scenarios, the handling of e-Invoices is as follows:
Scenario 1
Since the primary policy exists between the insurance company and the intermediary, the insurance companies are responsible for issuing e-Invoices to the intermediary rather than directly to end customers. Consequently, the intermediary should issue e-Invoices to end customers for the premiums received. If the intermediary does not issue e-Invoices to end customers for the premiums received, the insurance company should then issue e-Invoices directly to the end customers instead of to the intermediary.
Scenario 2
If the contract is between the insurance company and the end customer as the policyholder (where the intermediary is not the policyholder), the e-Invoice must be issued directly to the policyholder, who is the end customer.
After the policy is terminated, must the insurance company issue a refund invoice to the policyholder for the return of the premium?
In cases where policy termination includes a refund to the policyholder, an e-Invoice for a refund note must be issued according to the company’s existing billing and invoicing procedures, with the following exceptions:
1. Incorrect payments made by policyholders
2. Overpayments made by policyholders
3. Return of security deposits
Whose details should be used as the Buyer’s details for issuing an e-Invoice when the policyholder is under 18 years of age?
Generally, for e-Invoicing purposes, the Buyer is typically the policyholder. However, in cases where the policyholder is a minor, the Buyer’s details should instead reflect those of the parent, guardian, or any other relevant party involved.
Currently, customers have the option to request separate invoices for each entity under the master group policy to clarify the premium amounts payable or paid. With the implementation of e-Invoice, will this existing practice continue, or should the e-Invoice be issued exclusively to the master policyholder?
Generally, for e-Invoicing, the Buyer is typically the policyholder. If policies are individually issued to each group entity, e-Invoices should be issued to each respective entity. In a single group policy, the e-Invoice would be issued to the master policyholder. However, to accommodate customer requests for separate e-Invoices for each entity under the master group policy, insurance companies may issue separate e-Invoices based on their current business processes.
In cases where the employer collects insurance contributions from their employees and then pays them to the insurance company, to whom should the insurance company issue the e-Invoice: the employee or the employer?
For e-Invoicing purposes, the Buyer typically refers to the policyholder as a general principle. If the policyholder is the employee, the insurance company should continue issuing the e-Invoice to the employee. It’s important to note that the collection of insurance contributions by employers serves as a settlement mechanism for the insurance policy.
Cash before cover: With exceptions for certain products, insurance and takaful companies generally adhere to a policy of cash before cover. This means that the insured individual must make payment before the policy is issued. Currently, for business-to-business (B2B) and group business transactions, invoices are issued upon policy issuance or when the premium is due. For business-to-consumer (B2C) transactions such as life, medical, and education policies, an annual statement is typically issued. With the implementation of e-Invoice, will this existing practice continue?
The current procedures can be maintained for e-Invoice purposes.
C. Claims and benefits payment
How are e-Invoices handled for insurance claims, compensation, and benefit payments (such as maturity benefits or other forms of payouts based on product features) issued by insurance companies to policyholders or beneficiaries?
Insurance companies must issue self-billed e-Invoices for insurance claims, compensation, and benefit payments to the policyholder or beneficiary, regardless of whether they are an individual or a business. In the context of self-billed e-Invoices, the policyholder or beneficiary is considered the supplier, even if the payment is made to third parties such as hospitals, workshops, or attorneys. Additionally, insurance companies are permitted to issue consolidated self-billed e-Invoices for claims and benefit payments to individuals not engaged in business activities.
Is it necessary to issue an e-Invoice to workshops or salvage contractors for the disposal of scrap or wreckage from damaged assets?
The e-Invoice treatment should depend on the ownership of the damaged assets:
- If the insurance company takes ownership of the damaged assets from the policyholder upon compensation claim and then disposes of them, the insurance company must issue an e-Invoice to the workshops or salvage contractors for the disposal.
- If the policyholder retains ownership of the assets (e.g., company, limited liability partnership, partnership, business conducted by an individual), the policyholder must issue an e-Invoice to the workshops or salvage contractors for the disposal of the damaged assets.
- If the policyholder is an individual not conducting business, a non-Malaysian individual, a foreign company not operating or established in Malaysia, or a person exempted under Section 1.6.1 of the e-Invoice Guideline, the workshop or salvage contractor must issue a self-billed e-Invoice.
A Knock-for-Knock arrangement allows policyholders to file a claim with their own insurer while an accident investigation is ongoing involving another vehicle (e.g., Vehicle A and Vehicle B in this scenario). After the investigation concludes and Driver B is found to be at fault, Driver A’s insurance company can recover the claim payment made to its policyholder from Driver B’s insurance company. With the implementation of e-Invoicing, what is the e-Invoice treatment for this type of transaction?
For insurance claims received by Driver A and Driver B from their respective insurance companies, please refer to Question No. 1 under Part C – Claims and Benefit Payments for the appropriate e-Invoice treatment.
Regarding the recoupment of the claim from Driver B’s insurance company to Driver A’s insurance company, Driver B’s insurance company must issue a self-billed e-Invoice to the policyholder (i.e., Driver B), even if the payment is made to Driver A’s insurance company.
Insurance companies are permitted to issue consolidated self-billed e-Invoices for claims and benefit payments to individuals not conducting business.
D. Payment to agents, dealers and distributors
If an insurance company pays registration or examination fees on behalf of agents to the Insurance Association or Examination Body and subsequently recovers this amount from the agents, is this considered a pass-through, thereby exempting the insurance company from issuing an e-Invoice to the agents?
If the e-Invoice for the registration or examination fees is issued by the Insurance Association or Examination Body to the insurance company, the IRBM requires that the payment made on behalf of the agent be included in the e-Invoice issued by the insurance company to the agents. Note that the amount recovered by the insurance company from their agents will not be recognized as the insurance company’s income, and the appropriate classification code should be selected by the insurance company.
If the e-Invoice for the registration or examination fees is issued directly to the agents by the Insurance Association or Examination Body, this amount does not need to be included in the e-Invoice issued by the insurance company.
E. Others
Are charges between funds (such as investment-linked policy charges, wakalah fees, qard, actuarial surplus transfer, etc.) required to be processed through e-Invoicing?
e-Invoicing is not mandatory for interfund charges since these transactions occur within the same legal entity. However, if an insurance company currently issues invoices to document these transactions, they may continue this practice after implementing e-Invoicing.
Transition-related concerns: How should policy endorsements issued post- e-Invoicing implementation be managed regarding the IRBM unique identifier number?
If an insurance company issues a new e-Invoice for a policy endorsement, no reference to the original invoice (issued before e-Invoicing implementation) or original e-Invoice is necessary.
However, if the insurance company issues a debit note, credit note, or refund note e-Invoice for the policy endorsement, they must complete the “Original e-Invoice Reference Number” field as follows:
– For original invoices issued before e-Invoice implementation: Enter “NA”.
– For original e-Invoices: Enter the relevant IRBM unique identifier number of the original e-Invoices.
Implementation Of E-Invoice In Malaysia
Frequently Asked Questions (FAQs) For Aviation Industry
How should an e-Invoice be issued for the sale of flight tickets or the provision of private air charter services?
Issuing an e-Invoice is mandatory for the sale of flight tickets and private air charter services as follows:
a) Local airline operators: All flight tickets and private air charter services must be e-Invoiced, regardless of the point-of-sale.
b) Foreign airline operators: E-Invoices are required for flight tickets and private air charter services when the point-of-sale is in Malaysia.
Note: The point-of-sale is determined by the International Air Transport Association (IATA).
Also, consolidated e-Invoices are not allowed for flight tickets or private air charters.
Whose details should be provided as the Buyer when issuing an e-Invoice for the sale of a flight ticket or private air charter?
When issuing an e-Invoice for the sale of a flight ticket or private air charter, the Buyer’s details should be provided as follows:
a) Individual Purchases: If an individual buys a ticket for personal travel or for another individual who is the passenger, the Buyer’s details should reflect the person who made the purchase.
b) Group Purchases: For multiple tickets in a single booking, the Buyer’s details can be one of the following, based on the Supplier’s preference:
- The details of the person who made the purchase, for all individual e-Invoices.
- The details of each passenger within the booking, for their respective individual e-Invoice.
Whose details should be provided as the Buyer when issuing an e-Invoice for the sale of a flight ticket or private air charter?
The IRBM acknowledges the difficulty in obtaining personal information from buyers in the aviation industry due to specific data protection regulations. Therefore, IRBM has temporarily allowed Suppliers to use the following details for Buyers of flight tickets or private air charters that do not require an e-Invoice:
i. Buyer’s Name: Suppliers should input “General Public” in the e-Invoice.
ii. Buyer’s Tax Identification Number: Suppliers should input “EI00000000020” in the e-Invoice, regardless of whether the Buyer is local or foreign.
iii. Buyer’s Business Registration Number (BRN): Suppliers should input “NA” in the e-Invoice, regardless of whether the Buyer is an individual or business.
iv. Other Buyer’s Details (Address, Contact Number, SST Registration Number): Suppliers should input “NA” in the e-Invoice.
If a passenger exceeds the baggage limit, they may need to purchase excess baggage at the check-in counter. How should e-Invoices be handled for excess baggage fees charged to the passenger in this instance?
When an airline operator charges a passenger an excess baggage fee, the operator is responsible for issuing:
i. An e-Invoice (upon request), or
ii. A receipt (if no e-Invoice is requested)
for the transaction completed at the counter. If a receipt is issued
(iii) the airline operator must aggregate these transactions and issue a consolidated e-Invoice within seven (7) days from the end of the month.
How should e-Invoices be handled in the event of price changes to a flight ticket (e.g., increases, reductions, or refunds) due to flight changes or cancellations?
The airline operator is responsible for issuing e-Invoices to Buyers as follows:
i. Price Increase: If the new price is higher than the previous flight, an e-Invoice (either an invoice or debit note, as applicable) must be issued for the difference in amount.
ii. Price Reduction: If the price is reduced compared to the previous flight, an e-Invoice (either a credit note or refund note, as applicable) should be issued.
If there is no change in monetary value due to flight cancellations or changes, no additional e-Invoices are required. The airline operator may continue to issue e-Invoices with a nil amount as per current invoicing practices.
How are e-Invoices handled for the sale of flight-related extras (like seat selection and baggage) and non-flight extras (such as travel insurance, car rentals, and hotels) when sold by airlines, regardless of whether they are bought together with a flight ticket or separately?
The approach to e-Invoicing for the sale of flight-related and non-flight ancillaries by airline operators is outlined as follows:
For Flight-Related Ancillaries:
a. When a flight ticket and related ancillaries are purchased together in one transaction, airlines have two options for e-Invoicing, based on their preference:
- Issue a single e-Invoice that covers both the flight ticket and the ancillaries.
- Issue separate e-Invoices for the flight ticket and for the ancillaries.
b. When a flight ticket and related ancillaries are purchased separately, airlines must:
- Always issue an e-Invoice for the flight ticket.
- Issue an e-Invoice for the ancillaries upon the buyer’s request or provide a receipt if no e-Invoice is requested.
For non-flight ancillaries:
The obligation to issue an e-Invoice depends on the contractual relationship between the airline and the third-party service provider.
a. If the airline sells non-flight ancillaries as the principal party: a. If the flight ticket and non-flight ancillaries are sold together in one transaction, the airline must:
Issue one e-Invoice detailing both the flight ticket and the non-flight ancillaries,
or
Issue separate e-Invoices for the flight ticket and the non-flight ancillaries.
b. If the flight ticket and non-flight ancillaries are sold separately, the airline must:
- Always issue an e-Invoice for the flight ticket.
- Issue an e-Invoice for the non-flight ancillaries upon the buyer’s request or provide a receipt if no e-Invoice is requested.
If the airline acts merely as an agent for the sale of non-flight ancillaries on behalf of a service provider, then it is the service provider’s responsibility to:
Issue an e-Invoice upon the buyer’s request or provide a receipt if no e-Invoice is requested.
Implementation Of E-Invoice In Malaysia
Frequently Asked Questions (FAQs) For Tourism Industry
Who is accountable for issuing e-Invoices for flight tickets or private air charters when they are sold via travel agents or other third-party sellers?
The duty to issue an e-Invoice for flight tickets or private air charters sold through travel agents or third parties hinges on the nature of the contractual relationship between the airline operator and the travel agent or third party.
1. When the travel agent is the principal (buys from the airline and sells to the consumer), it’s the travel agent’s responsibility to provide the consumer with an e-Invoice. This includes scenarios where:
a. A flight ticket and other non-flight services (like ground tours or visa applications) are bundled in a single sale. Here, the travel agent must issue:
– A single e-Invoice covering both the flight and non-flight services, or
– Separate e-Invoices for the flight ticket and each non-flight service.
b. When flight tickets and non-flight services are sold individually, the travel agent must issue:
– An e-Invoice for the flight ticket, mandatory for all sales, and
– An e-Invoice for any non-flight services upon the consumer’s request or a receipt if no e-Invoice is requested.
The airline operator will issue an e-Invoice to the travel agent for the purchase of flight tickets or private air charters, maintaining the existing invoicing practices.
2. If the travel agent sells flight tickets on behalf of the airline operator (acting as an agent), the airline operator is responsible for issuing an e-Invoice to the consumer for both flight tickets and private air charters.
Additionally, the airline operator must issue a self-billed e-Invoice for any commissions paid to the travel agent, in line with Section 9 of the e-Invoice Specific Guideline.
It’s important to note that consolidated e-Invoices are not permitted for the sale of flight tickets or private air charters.
Who should be listed as the Buyer when a travel agent, serving as the principal, issues an e-Invoice for a flight ticket or private air charter sale?
When issuing an e-Invoice for the sale of a flight ticket or private air charter, the information of the Buyer should be recorded as follows:
a) If the purchase is made by an individual either for their own travel or on behalf of another individual who is the passenger, the Buyer’s information should be that of the individual who completed the purchase.
b) In the case of group purchases (where multiple tickets are bought in a single transaction), the Buyer’s information can be handled in one of two ways, depending on the preference of the Seller:
i. Use the information of the individual who made the purchase for all the e-Invoices issued for each ticket.
ii. Include the information of each individual passenger from the booking on their respective e-Invoices.
When a travel agent sells a 4-day 3-night tour package to Penang for RM1,500 and requires a 20% security deposit at the time of booking, with the balance 80% to be paid one week before departure, how should the issuance of an e-Invoice be handled in situations involving the collection of a deposit?
When the collected deposit is refundable, there is no need to issue an e-Invoice upon receiving the security deposit. However, if the deposit is non-refundable, the travel agent must issue an e-Invoice for the amount of the deposit collected. Following this, a separate e-Invoice should be issued for the remaining balance amount.
A Malaysian travel agency collaborates with third-party tour guides (both domestic and international) to include tour guide services as an integral component of the travel packages they sell. At present, these tour guides send invoices to the travel agency for the services they render. How should e-Invoicing be handled in the context of these transactions?
When a service is rendered by a local tour guide, it is mandatory for the tour guide to issue an e-Invoice to the travel agency for the provided services. Conversely, if a foreign tour guide provides the service, the Malaysian travel agency must generate a self-billed e-Invoice for the transaction. For further information on the process of issuing self-billed e-Invoices, please consult Section 8 of the e-Invoice Specific Guideline.
Can a travel agency issue a single e-Invoice for tour packages that bundle various services (such as flight tickets, hotel stays, and tour guide services) at a combined price to customers who do not request an e-Invoice?
If a tour package includes a flight ticket, the travel agency must issue separate e-Invoices for each customer, regardless of whether the customer has asked for an e-Invoice or not. However, if the tour package does not include a flight ticket, the travel agency may provide receipts to customers who do not specifically request an e-Invoice. In such cases, the agency is permitted to compile all transactions and submit a consolidated e-Invoice for validation by the IRBM within seven days following the end of the month.
It’s important to note that consolidated e-Invoices cannot be issued for the sale of flight tickets or private air charters.
Implementation Of E-Invoice In Malaysia
Frequently Asked Questions (FAQs) For Financial Services, Stockbroking and Unit Trust
A. Financial services
Under the Financial Services Act 2013 (FSA) and Islamic Financial Services Act 2013 (IFSA), financial institutions are obligated to maintain confidentiality regarding their customers’ account details and personal affairs. With the adoption of e-Invoicing, is it necessary for financial institutions to secure consent from their customers before issuing individual e-Invoices?
To adhere to the confidentiality obligations outlined in the FSA and IFSA, financial institutions are required to secure their customers’ approval before issuing e-Invoices.
According to Section 4.3.7 of the e-Invoice Specific Guideline, within regulated sectors, including financial institutions, there is no requirement to include the statement or bill reference number in the “Description of Product or Service” section of the consolidated e-Invoice. Given this, what is the appropriate way to fill in this field?
In the consolidated e-Invoice, financial institutions must enter relevant and suitable descriptions in the “Description of Product or Service” section.
Is it mandatory for financial institutions to generate e-Invoices for revenue obtained from foreign branches?
A resident company engaged in banking must issue e-Invoices for operations both within and outside Malaysia.
Following the adoption of e-Invoicing, do customers of financial institutions need to issue e-Invoices to these institutions for received income (for example, interest earned from fixed deposits)?
When customers ask for an e-Invoice, financial institutions must provide one to their clients. This e-Invoice may resemble regular statements or bills and will itemize the customer’s liabilities (such as transaction fees) along with any payments or credits to the customer (for instance, rebates, interest earned on deposits, etc.).
Are financial institutions permitted to generate a consolidated e-Invoice to document the revenue from financial services offered to clients who do not request an e-Invoice, including walk-in customers?
Yes, financial institutions have the permission to generate a consolidated e-Invoice for transactions in cases where customers do not request an e-Invoice, except when the activities or transactions are covered by Section 3.7 of the e-Invoice Specific Guideline.
Financial institutions offer loans to individuals and businesses for financing needs, applying interest to the loaned sum. Borrowers must then make repayments of the principal amount in installments, along with the interest. With the introduction of e-Invoicing, is it necessary for the financial institution to issue an e-Invoice covering both the principal and the interest charges?
Financial institutions must generate an e-Invoice for the interest incurred. Nonetheless, issuing an e-Invoice for the repayment of the loan principal is not necessary.
How is e-Invoicing applied to interest generated from interbank lending and borrowing?
The lending bank is obligated to generate an e-Invoice for the interest it charges to the borrowing bank.
How is e-Invoicing applied to premiums or upfront fees associated with treasury products, as well as products or services compliant with Shariah?
An e-Invoice must be generated for the premium or upfront fee when the premium or fee is non-refundable.
How does e-Invoicing apply to accounts with multiple account holders, including but not limited to: – Joint accounts, – Omnibus accounts, – Custodial accounts, including those for minors, – Trust accounts, – Estate accounts, – Escrow accounts?
The current method of generating one e-Invoice for an account shared by several parties remains applicable. In cases of joint account ownership, the main account holder, to whom the financial institution sends statements, should be identified as the Buyer on the e-Invoice. However, should any of the other co-owners desire their own e-Invoice, the financial institution is obliged to issue individual e-Invoices to these additional account holders.
How are e-Invoices managed for various charges and fees, such as transaction fees, interchange fees, switching fees, assessment fees, and monthly fees, that are paid to card network processors (like Visa, Mastercard, etc.) both internationally and domestically, as well as other payment operators (such as PayNet, UnionPay, PayPal, etc.)?
Financial institutions must generate self-billed e-Invoices for any fees and charges paid to overseas card network processors and operators. Conversely, domestic card network processors and operators are tasked with issuing e-Invoices for any fees or charges they receive from financial institutions. If domestic card network processors and operators are already providing statements or bills to financial institutions, they are permitted to produce e-Invoices in XML or JSON format. These e-Invoices can detail the amounts due from financial institutions, along with any payments or credits to them, and can be transformed into a visual format resembling traditional statements or bills after validation.
In the context of an inward remittance transaction where funds are transferred to a recipient from a sender through a correspondent agent located outside Malaysia (for instance, a Nostro agent or an intermediary to the Nostro agent), the foreign agent levies a processing or transfer fee on the financial institution. This fee is then passed on to the local recipient by the financial institution. With the adoption of e-Invoicing, the question arises on the proper method for issuing an e-Invoice for this processing or transfer fee.
The financial institution must generate a self-billed e-Invoice for the processing or transfer fee to the foreign agent. Following this, if the processing or transfer fee is passed on to the local recipient, the financial institution is obligated to issue an e-Invoice for the said fee.
With the introduction of e-Invoicing, is it mandatory for financial institutions to generate e-Invoices for advance payments received from participants in auctions or bidding processes for foreclosed properties?
An e-Invoice must be issued in cases where the upfront payment is non-refundable. However, if the upfront payment is refundable, there is no requirement to issue an e-Invoice at the time the payment is received.
At present, financial institutions provide cashback incentives to cardholders as a component of their card rewards program. With the adoption of e-Invoicing, how should cashbacks given to cardholders be handled in terms of e-Invoicing?
Financial institutions have the permission to generate an e-Invoice in either XML or JSON format. This e-Invoice can detail both the amounts due from cardholders and any payments or credits made to them (for example, cashback redemptions or payouts). Following validation, these e-Invoices can then be transformed into a visual format, resembling traditional statements or bills.
Besides cashbacks, financial institutions also offer reward points that cardholders can exchange for goods, services, or air miles. With the introduction of e-Invoicing, how should the redemption of goods, services, or air miles by cardholders be processed in terms of e-Invoicing?
When financial institutions grant reward points to cardholders at no cost, there is no requirement for issuing an e-Invoice or a self-billed e-Invoice. Similarly, for the redemption of goods or services using these reward points, financial institutions are not obligated to issue an e-Invoice or a self-billed e-Invoice to cardholders.
However, should there be any additional fees not covered by the reward points (such as administrative fees or extra costs for goods or services), financial institutions must issue an e-Invoice to the cardholders for these charges.
In cases where these additional charges are already included in the statements or bills provided by financial institutions, they are permitted to issue an e-Invoice in XML or JSON format. This e-Invoice will detail both the charges owed by cardholders (like those additional fees for redemption) and any payments or credits to cardholders. After validation, this e-Invoice can be converted into a visually formatted statement or bill.
Can financial institutions incorporate adjustments to previously issued e-Invoices in the e-Invoice of the following month, rather than issuing a credit note, debit note, or refund note e-Invoice, as applicable?
Yes, given that financial institutions already issue statements or bills, they are permitted to incorporate adjustments into the next month’s e-Invoice. This e-Invoice, which can be in XML or JSON format, will cover both the amounts due from clients and any payments or credits to clients. After validation, this e-Invoice can then be transformed into a visual format, resembling traditional statements or bills.
Is it necessary to issue an e-Invoice for income or gains from the following treasury products (this also applies to Shariah-compliant products or services), where invoices are not typically issued: – Realized income or gains/losses from the sale of shares, equity options, warrants, etc., – Unrealized income or expenses from marking-to-market shares, equity options, warrants, etc., – Amortization or accretion of premiums, fees, or reserves, – Gains and losses from foreign exchange (FX)?
There’s no obligation to issue e-Invoices for adjustments made during accounting or auditing processes. Firms can adhere to their existing procedures for managing these adjustments, which include, but are not limited to, the following areas:
- Any gains or losses (whether realised or unrealised)
- Amortisation / Accretion of premium, fee or reserve
- FX gains or losses
B. Securities and derivatives broking
Please note: In this section, the term “broker(s)” encompasses all participants of Bursa Malaysia, such as Participating Organisations, Trading Participants, Trading Clearing Participants, Clearing Participants, Authorised Depository Agents, and Authorised Depository Members.
Is it necessary to issue an e-Invoice for the trading of securities and/or derivatives on domestic and/or international stock exchanges or derivatives exchanges?
The purchase and sale of securities and/or derivatives on a stock exchange or derivatives exchange, whether in Malaysia or abroad, are presently exempt from the requirement of an e-Invoice.
Be aware that this exemption is subject to periodic review and updates.
At present, brokers provide their clients with the following documents: (a) Contract note or statement; and (b) Monthly account statement. Which of these documents needs to be submitted for e-Invoice purposes?
Brokers, who are currently providing their clients with statements or bills, have the permission to generate e-Invoices in either XML or JSON format. These e-Invoices can encompass both the amounts due from clients and any payments or credits to clients within the same document. Additionally, brokers can transform the validated e-Invoice into a visually presentable format, such as statements or bills (this could be a contract note, statement, or monthly account statement).
Given that brokers must keep the confidentiality of transactions governed by the Capital Markets and Services Act 2007 and the Securities Industries (Central Depositories) Act 1991, is it necessary for brokers to reveal the statement or bill reference number in the “Description of Product/Service” section of the consolidated e-Invoice?
Therefore, brokers are not obligated to reveal the statement or bill reference number in the “Description of Product/Service” section of the consolidated e-Invoice. Nonetheless, when issuing a consolidated e-Invoice, brokers must ensure that the descriptions entered in this field are relevant and suitable.
How are fees charged by brokers to their customers, such as brokerage fees, rollover fees, handling fees for investor’s trust, clearing fees, etc., treated in the e-Invoice system?
When brokers levy fees on their investors, it is the broker’s duty to issue:
i. An e-Invoice (when requested); or
ii. A receipt (if an e-Invoice is not requested) to the investors, followed by the issuance of a consolidated e-Invoice.
At present, brokers incorporate collections made on behalf (such as stamp duty, third-party fees, etc.) into the contract note or statement provided to their investors, along with any other fees the broker charges. With the introduction of e-Invoice, will this approach remain in effect, or will brokers need to alter their existing practices?
When a third party provides an e-Invoice or invoice to the broker for collections made on behalf (such as stamp duty, third-party fees, etc.), these collections must be incorporated into the e-Invoice that the broker issues to the investors. The broker must enter the correct classification code for these collections.
Conversely, if the third party sends an e-Invoice or invoice directly to the investors for these collections, there is no need for the broker to include these collections in the e-Invoice issued to the investors.
How are the following fees related to the Central Depository System (CDS), charged by Bursa Malaysia Depository Sdn Bhd (BMDep), treated in the e-Invoice system: (a) Fees for opening an account (b) Fees for transfers (c) Fee for Transmission of Title (TOT)?
With the adoption of the e-Invoice system, BMDep must issue an e-Invoice for the fees it charges.
Is it mandatory for Authorised Depository Agents (ADAs) to issue an e-Invoice for income derived from rebates related to CDS fees?
Yes, it is obligatory for Authorised Depository Agents (ADAs) to issue an e-Invoice for the rebates they receive.
At present, a nominee company handles corporate actions (such as dividends, rights issues, etc.) for its clients, disbursing the net dividend after deducting administrative or processing fees. How are the foreign dividends received on behalf of the nominee company’s clients, along with the administrative or processing fees, treated under the e-Invoice system?
The procedures for e-Invoice are as detailed below:
• The client in question must issue an e-Invoice (where applicable) for the foreign dividend income obtained from the distributor of the foreign dividend.
• The nominee company must issue an e-Invoice for the administrative or processing fees it levies on its clients.
How is the e-Invoice managed for interest income earned by a broker from depositing clients’ trust funds in financial institutions, which is subsequently distributed to clients after subtracting handling fees?
The procedures for e-Invoice are as follows:
• The domestic financial institution disbursing the interest must generate an e-Invoice for the account holder. When the interest is paid by an international financial institution, it’s the responsibility of the account holder to create an e-Invoice for the received interest.
• The broker must generate a self-billed e-Invoice for the total amount of interest owed to the clients (that is, before the deduction of handling fees) and issue another e-Invoice specifically for the handling fees applied to its clients.
At present, Bursa Malaysia Securities Berhad (BMS) imposes initial listing fees on the issuers of structured warrants and exchange-traded funds. These initial fees are subsequently reimbursed by BMS to the issuers as a rebate, provided the issuers meet certain conditions set by BMS. To request this rebate, issuers must submit a declaration to BMS. What is the approach for handling the e-Invoice for this rebate?
BMS must generate a refund note e-Invoice for the initial listing fees that are reimbursed to the issuers.
How is the e-Invoice processed for the commission that brokers pay to the Commissioned Dealer’s Representative (i.e., remisier)?
In line with Section 9 of the e-Invoice Specific Guideline, brokers must generate a self-billed e-Invoice for the commission paid to the Commissioned Dealer’s Representative.
At present, BMDep levies CDS fees on the nominee company for beneficiaries opening CDS accounts in the name of the nominee company. How should the e-Invoice be handled for these CDS fees?
BMDep must generate an e-Invoice for the nominee company for the charged CDS fees. Following this, the nominee companies are obligated to issue an e-Invoice to the beneficiaries for the CDS fees that are passed on to them.
According to the Securities Commission (Levy on Securities Transactions) Order 1995, a levy of 0.015% on the value of transactions, whether purchases or sales, is due to the Securities Commission (SC Levy), with brokers responsible for paying half of this levy as stipulated by BMS Rules. Presently, BMS invoices the brokers and collects this segment of the SC Levy on behalf of the Securities Commission (SC). With the adoption of e-Invoice, will this procedure remain unchanged, or will BMS need to adjust its existing method?
With the introduction of e-Invoice, the process for issuing e-Invoices is expected to mirror the existing invoicing arrangement. In instances where the Securities Commission (SC) issues an e-Invoice, invoice, or any other form of documentation for collections conducted on behalf of BMS, these collections need to be reflected in the e-Invoice that BMS issues to brokers. Furthermore, BMS must apply the correct classification code for the aforementioned collection on behalf.
C. Unit Trust-Related Transactions
The Institutional Unit Trust Advisor (IUTA) serves as a go-between for end investors and the Unit Trust Management Company (UTMC), facilitating the purchase of unit trust fund (UTF) units for end investors through UTMC. UTMC levies a sales charge on IUTA, which in turn, IUTA passes on as a sales charge to the end investors. With the adoption of e-Invoice, how should the sales charge be addressed in the e-Invoice process?
The handling of e-Invoices is as follows:
- For the transaction between UTMC and IUTA, UTMC must generate an e-Invoice for the sales charge applied to IUTA.
- For the transaction between IUTA and the end investors, IUTA must generate an e-Invoice for the sales charge applied to the end investors.
Regarding the scenario where dividends from Unit Trust Fund (UTF) investments are distributed, the process involves UTMC disbursing payments to IUTA, who then forwards the dividend income to the end investors. In this context, what is the appropriate method for issuing an e-Invoice?
The process for e-Invoice issuance is as follows:
- For the transaction between UTMC and IUTA, UTMC must generate a self-billed e-Invoice for the dividends paid out to IUTA.
- For the transaction between IUTA and the end investors, IUTA must generate a self-billed e-Invoice for the dividends passed on to the end investors.
UTMC levies a management fee on the local Unit Trust Fund (UTF), a cost that is ultimately covered by the end investors. Furthermore, UTMC offers rebates on these management fees to specific qualified end investors, who may be either individuals or corporate entities. With the transition to e-Invoice, how should the e-Invoice process address the management fees incurred and the rebates awarded?
The approach for e-Invoice processing is outlined as follows:
For the Management Fees:
- UTMC must generate an e-Invoice for the management fee charged to the UTF. Subsequently, UTF must issue e-Invoices to the end investors, reflecting their share of the management fee.
For Management Fee Rebates:
- Since rebates are provided directly to the eligible end investors, UTMC must issue either a credit note or refund note e-Invoice to those investors. When creating the credit or refund note e-Invoice, UTMC must include the IRBM Unique Identifier Number from the original e-Invoice that was issued by UTMC to UTF for the management fee. This number should be entered in the “Original e-Invoice Reference Number” field.
In a Fund of Funds (FoF) structure, a local Unit Trust Fund (UTF) invests in a collection of foreign investment funds, such as foreign UTFs. The management fee for the foreign UTF is charged by the foreign fund manager and is indirectly paid by its investors, which include the local UTF and, by extension, the local UTF’s end investors. To prevent a double management fee charge to the local end investors, the foreign fund manager issues rebates on the management fees to the local Unit Trust Management Company (UTMC), which then passes these rebates on to the local UTF. With the shift to e-Invoice, how should the e-Invoice process handle the provided rebates?
The procedures for e-Invoice handling are as follows:
For Management Fees Charged by the Foreign UTF:
- The local Unit Trust Management Company (UTMC) must generate a self-billed e-Invoice for the management fee levied by the foreign UTF.
- The local UTMC must then issue an e-Invoice to the local UTF for the management fee charged by the foreign UTF. Following this, the local UTF is obligated to issue e-Invoices to the end investors, detailing their respective shares of the management fee.
For Management Fee Rebates:
- The local UTMC must create a self-billed credit note e-Invoice for the rebates received.
- Since the rebate is allocated directly to the qualified end investors of the local UTF, the local UTMC must issue either a credit note or refund note e-Invoice to these investors. When creating this e-Invoice, the local UTMC must insert the IRBM Unique Identifier Number from the original e-Invoice, which was issued by the local UTMC to the local UTF for the management fee, into the “Original e-Invoice Reference Number” field.
End investors have the option to invest RM1,000 via UTMC without incurring any commission or sales charge from UTMC. Upon successfully finalizing a sales booking, UTMC provides a confirmation transaction slip. In scenarios where UTMC does not generate any revenue, is there still a requirement to issue an e-Invoice?
An e-Invoice does not need to be issued if there are no commission or sales charges resulting from the investment transaction. Nonetheless, UTMC has the option to issue an e-Invoice indicating a ‘Nil’ amount, should they choose to do so.
In the case of a Private Retirement Scheme (PRS) fund, the Private Pension Administrator (PPA) levies a PPA fee on the end investors. At present, PPA sends an invoice to UTMC for the total PPA fees, after which UTMC bills the PRS end investors for the PPA fee. With the adoption of e-Invoice, how should the e-Invoice process manage the PPA fee imposed on PRS end investors?
With the introduction of e-Invoice, UTMC must generate an e-Invoice for PRS end investors detailing the PPA fees that UTMC has charged.