Understanding the LHDN e-Invoice Guideline: What Malaysian Businesses Need to Know

1.0 INTRODUCTION 

To support the growth of the digital economy, the Government intends to implement  e-Invoice in stages in an effort to enhance the efficiency of Malaysia’s tax  administration management. It is in line with the Twelfth Malaysia Plan, where the  focus is on strengthening the digital services infrastructure and digitalising the tax  administration. 

The e-Invoice will enable near real-time validation and storage of transactions,  catering to Business-to-Business (B2B), Business-to-Consumer (B2C) and  Business-to-Government (B2G) transactions. 

1.1 About e-Invoice 

An e-Invoice is a digital representation of a transaction between a supplier and  a buyer. e-Invoice replaces paper or electronic documents such as invoices,  credit notes, and debit notes. 

An e-Invoice contains the same essential information as traditional document,  for example, supplier’s and buyer’s details, item description, quantity, price excluding tax, tax, and total amount, which records transaction data for daily business operations. 

Figure 1.1 explains what an e-Invoice is and what an e-Invoice is not:

Figure 1.1 – What an e-Invoice is and what an e-Invoice is not 

1.2 Benefits of Adopting e-Invoice 

The implementation of e-Invoice not only provides seamless experience to  taxpayers, but also improves business efficiency and increases tax compliance. Overall benefits include: 

1. Unified invoicing process through the streamlining of transaction document  creation, and submission of data electronically to IRBM. The automation of  data entry for transactions reduces manual efforts and human errors; 

2. Facilitate tax return filing through seamless system integration for efficient  and accurate tax reporting; 

3. For larger businesses, the adoption of e-Invoice enables the streamlining of  operations, resulting enhanced efficiency and significant time as well as cost  savings through automated processes, seamless data integration, and  improved invoice management; and 

4. For micro, small and medium-sized enterprises (MSMEs), the phased  implementation offers a progressive and manageable transition to e-Invoice,  allowing MSMEs to align their financial reporting and processes to be  digitalised with industry standards, ensuring that MSMEs to adapt over a  longer period and mitigating potential disruptions.

1.3 Transaction Types  

e-Invoice covers typical transaction types such as B2B, B2C, and B2G. For B2G  transactions, the e-Invoice flow will be similar to B2B. 

e-Invoice applies to all persons in Malaysia. 

All individuals and legal entities are required to comply with e-Invoice requirement, including: 

1. Association; 

2. Body of persons; 

3. Branch; 

4. Business trust; 

5. Co-operative societies; 

6. Corporations; 

7. Limited liability partnership; 

8. Partnership; 

9. Property trust fund;  

10. Property trust; 

11. Real estate investment trust; 

12. Representative office and regional office; 

13. Trust body; and 

14. Unit trust. 

1.4 Scenarios and Types of e-Invoices 

The e-Invoice model ensures a comprehensive and standardised approach to  generation, transmission, and recordkeeping of transaction documents.  Transactions that fall under e-Invoice implementation are driven by the following  scenarios and invoice types. 

Scenarios requiring e-Invoice to be issued: 

1. Proof of Income: This document is issued whenever a sale or other transaction is made to recognise income of taxpayers; and 

2. Proof of Expense: This type of document covers purchases made or other  spending by taxpayers. It also includes returns and discounts. It can also be  used to correct or subtract an income receipt in terms of the amounts  documented. In addition, there are certain circumstances where taxpayers  would have to issue self-billed e-Invoice to document an expense such as  foreign transactions. For example, if the taxpayer acquired goods and/or  services from foreign supplier and received an invoice from the foreign  supplier who does not use Malaysia’s MyInvois System, the taxpayer would be required to issue a self-billed e-Invoice to document the expense. 

Types of e-Invoices to be issued: 

1. Invoice: A commercial document that itemises and records a transaction  between a Supplier and Buyer, including issuance of self-billed e-Invoice to  document an expense. 

2. Credit Note: A credit note is issued by Suppliers to correct errors, apply  discounts, or account for returns in a previously issued e-Invoice with the  purpose of reducing the value of the original e-Invoice. This is used in  situations where the reduction of the original e-Invoice does not involve 

return of monies to the Buyer; 

3. Debit Note: A debit note is issued to indicate additional charges on a  previously issued e-Invoice; and 

4. Refund Note: A refund note e-Invoice is a document issued by a Supplier  to confirm the refund of the Buyer’s payment. This is used in situations where  there is a return of monies to the Buyer.

Further details on the types of e-Invoices to be issued are outlined in the  Glossary section. 

Example 1 

Mr. Jamal (Supplier) made a sale of 200 office chairs to Greenz Sdn. Bhd.  (Buyer) and had issued an e-Invoice for the transaction. Greenz Sdn. Bhd. paid  RM2,000 for the 200 chairs (at RM10 per chair). However, 8 units of the office  chairs received by Greenz Sdn. Bhd. were faulty and had been returned. Mr. 

Jamal issued a refund note e-Invoice of RM80 (i.e., RM10 X 8 faulty chairs) to  document the refunded amount. 

1.5 e-Invoice Implementation Timeline  

e-Invoice will be implemented in phases to ensure smooth transition. The roll-out of  e-Invoice has been planned with careful consideration, taking into account the  turnover or revenue thresholds, to provide businesses with sufficient time to adapt. 

Below is the mandatory e-Invoice implementation timeline: 

Table 1.1 – Targeted taxpayers for each implementation target date

The annual turnover or revenue for the implementation of e-Invoice will be  determined based on the following: 

1. Taxpayers with audited financial statements: Based on annual turnover or  revenue stated in the statement of comprehensive income in the audited  financial statements for financial year 2022. 

2. Taxpayers without audited financial statements: Based on annual revenue  reported in the tax return for year of assessment 2022. 

3. In the event of a change of accounting year end for financial year 2022, the  taxpayer’s turnover or revenue will be pro-rated to a 12-month period for  purposes of determining the e-Invoice implementation date. 

Kindly note that for the purposes of the above determination, the annual turnover  or revenue will be based on 2022’s audited financial statements or tax return, as  the case may be. Once the taxpayer’s e-Invoice implementation timeline has  been determined, any changes to the taxpayer’s annual turnover or revenue in  subsequent years will not change the taxpayer’s obligations to implement 

e-Invoice based on the above-mentioned implementation timeline.  

For clarity, the compliance obligation is from the issuance of e-Invoice  perspective. In other words, taxpayers who are within the annual turnover or  revenue threshold as mentioned in Table 1.1 are required to issue and submit  e-Invoice for IRBM’s validation according to the implementation timeline. 

Any e-Invoice created and issued on or after the implementation date would be  required to be an e-Invoice issued in accordance with the requirements set by  IRBM. Invoices issued prior to e-Invoice implementation date applicable to the  taxpayers are not required to be converted into e-Invoice. 

As the compliance obligation of issuing e-Invoice lies with the Supplier (or the  Buyer in the case of self-billed e-invoice), taxpayers may receive either normal  receipt (if the Supplier has yet to implement e-Invoice in accordance with the  implementation timeline) or validated e-Invoice during the transitional period,  until full implementation has been in place. 

Nonetheless, taxpayers can opt to voluntarily participate in the implementation  of e-Invoice at an earlier date, regardless of their annual turnover or revenue. 

For new businesses or operations commencing from the year 2023 to 2024 with  an annual turnover or revenue of 

• more than RM500,000, the e-Invoice implementation date is 1 July 2025. • up to RM500,000, the e-Invoice implementation date is 1 January 2026.  

For new businesses or operations commencing from year 2025 onwards, the  e-Invoice implementation date is 1 January 2026 or upon the operation  commencement date.  

Example 2 

Company AZY changes the close of its accounting period from 30 June to 31  December. The original accounting period for financial year (FY) 2022 is from  1.7.2021 until 30.06.2022. The new accounting period after the change for  FY2022 is from 1.7.2021 until 31.12.2022 (18 months). Based on the FY2022  audited accounts for 18 months, its annual turnover is RM60 million. The  12-month average turnover of Company AZY for FY2022 is RM40 million (RM60  million / 18 months x 12 months) and confirmation on the mandatory e-Invoice  implementation date for Company AZY is 1 January 2025. 

1.6 Exemptions from implementing e-Invoice  

1.6.1 For the purposes of e-Invoice, the following persons are currently exempted from issuing e-Invoice (including issuance of self-billed  e-Invoice): 

(a) Foreign diplomatic office 

(b) Individual who is not conducting business 

(c) Statutory body, statutory authority and local authority, in relation to the  following: 

(i) collection of payment, fee, charge, statutory levy, summon,  compound and penalty by it in carrying out functions assigned to  it under any written law; and  

(ii) transaction of goods sold and services performed before 1 July  2025 

(d) International organisation for transaction of any goods sold or service  performed before 1 July 2025 (refer to Appendix 3 for the list of  international organisations) 

(e) Taxpayers with an annual turnover or revenue of less than  RM150,000. 

1.6.2 Hence, the above-mentioned persons are not required to issue an  e-Invoice (including self-billed e-Invoice). For tax purposes, the receipts /  any existing documents issued by the above-mentioned persons would  be used as proof of expense. 

1.6.3 For clarity, Suppliers who provide goods or services to the persons listed  in Section 1.6.1 above are required to issue e-Invoice, in accordance with  the implementation timeline in Section 1.5. 

1.6.4 However, in relation to transactions with persons in Section 1.6.1 (a) above, Suppliers are allowed to replace the Buyer’s details with the  information stated in Table 3.5 of the e-Invoice Specific Guideline.

1.6.5 The exemption in Section 1.6.1 will only be applicable to said persons. Any  entities (e.g., companies, limited liability partnership, etc.) owned by the  above-mentioned persons would still be required to implement e-Invoice, in accordance with the e-Invoice implementation timeline in  Section 1.5. 

1.6.6 Notwithstanding the exemption, the above-mentioned persons are  welcomed to implement e-Invoice, supporting the Government’s digital  initiative. 

1.6.7 The IRBM acknowledged there are various challenges in issuing e-Invoices for certain types of income or expense. To ease the adoption  of e-Invoice, an e-Invoice (including self-billed e-Invoice) is not required  for the following: 

(a) Employment income. 

(b) Pension. 

(c) Alimony. 

(d) Distribution of dividend in specific circumstances (Refer to Section 11 of e-Invoice Specific Guideline for more details). 

(e) Zakat. 

(f) Contract value for the buying or selling of securities or derivatives  traded on a stock exchange or derivatives exchange in Malaysia or  elsewhere. 

(g) Disposal of shares of a company incorporated in or outside Malaysia and not listed on the stock exchange, except where the disposer is a  company, limited liability partnership, trust body or co-operative  society.  

1.6.8 The exemptions mentioned in Section 1.6.1 and 1.6.7 will be reviewed  and updated from time to time.

2.0 GETTING READY FOR E-INVOICE 

2.1 e-Invoice Overview Workflow 

Figure 2.1 demonstrates an overview of the e-Invoice workflow from the point a  sale is made or transaction undertaken, and an e-Invoice is issued by the  supplier via MyInvois Portal or API, up to the point of storing validated e-Invoices on IRBM’s database for taxpayers to view their respective historical e-Invoices.  

Figure 2.1 – Typical workflow of e-Invoice in Malaysia 

2.2 e-Invoice Model 

To facilitate taxpayers’ transition to e-Invoice, IRBM has developed two (2)  distinct e-Invoice transmission mechanisms:  

a. A portal (MyInvois Portal) hosted by IRBM; and 

b. Application Programming Interface (API). 

Taxpayers can select the most suitable mechanism to transmit e-Invoice to  IRBM, based on their specific needs and business requirements. To assist  taxpayers in making an informed decision, Table 2.1 outlines the key features of and considerations for each option. 

Table 2.1 – Types of mechanism and key features

Figure 2.2 provides an overview of the e-Invoice workflow via MyInvois Portal  and/or API. 

Figure 2.2 – Overall e-Invoice workflow via MyInvois Portal and/or API 

Please refer to the relevant sections to gain a thorough understanding of the  respective e-Invoice process. 

2.3 e-Invoice model via MyInvois Portal 

MyInvois Portal contains all the functionalities required for taxpayers (Supplier)  to perform e-Invoice actions (i.e., generate, submit, view, cancel or reject  invoice, etc.) and is specifically designed for the following purposes:  

• Allows all taxpayers to view and search for their respective e-Invoices; and 

• Provides a platform to taxpayers who are not able to issue an e-Invoice on  their own system. 

Taxpayers are required to login to MyTax Portal to utilise MyInvois Portal to  perform their e-Invoice obligations in accordance with the rules and  requirements outlined by IRBM. 

Figure 2.3 showcases the e-Invoice model through the usage of MyInvois Portal.

Figure 2.3 – e-Invoice workflow via MyInvois Portal 

In the following section, each step in the Figure 2.3 of the e-Invoice model  workflow via MyInvois Portal will be elaborated to provide a comprehensive  understanding of its significance, function, and relationship to other steps. 

2.3.1 Pre-Submission – e-Invoice Submission Requirements 

How to Retrieve and Verify TIN 

To facilitate the retrieval and verification of TIN for taxpayers, there are two (2) primary avenues available: 

1. Utilise the MyTax Portal which allows businesses to conveniently  check their TIN; 

2. In the event that a TIN cannot be retrieved through this channel,  taxpayers can use the e-Daftar platform to initiate registration and  obtain their respective TIN via the steps below: 

a. Log in to MyTax Portal (https://mytax.hasil.gov.my)  

b. Choose the e-Daftar option 

c. Fill in the required fields (e.g., type of taxpayer, e-mail and phone  number / mobile number) 

d. Click “Search” to register taxpayer’s TIN  

2.3.2 Step 1 – Creation and Submission 

When a sale or transaction is concluded (including e-Invoice adjustments such as debit note, credit note and refund note), the Supplier creates an e-Invoice and submits it to IRBM via the MyInvois Portal for validation immediately. Supplier is to ensure the accuracy of the information  

included in the e-Invoice that is submitted to IRBM for validation, to the  extent possible. 

The MyInvois Portal will specify the mandatory and optional fields to facilitate taxpayers in filling out the data required for the issuance of  e-Invoice. For the list of data fields, refer to Appendix 1. 

Two (2) options are available:  

1. Individual Creation: Taxpayers can create e-Invoices individually by  completing a form with all the required fields; or 

2. Batch Upload: Taxpayers can upload a certain number of e-Invoices in batches by uploading pre-defined Microsoft Excel  spreadsheet to the portal, containing the necessary invoice  information.

Figure 2.4 – e-Invoice creation and submission workflow (MyInvois Portal) 

2.3.3 Step 2 – e-Invoice Validation 

Once validated (which is done in near real-time), the Supplier will receive  a validated e-Invoice as well as a visual representation of the validated  e-Invoice in PDF from IRBM via the MyInvois Portal. The IRBM Unique  Identifier Number, date and time of validation, and validation link will be  assigned to the validated e-Invoice. The IRBM Unique Identifier Number  will allow traceability by IRBM and will reduce instances of tampering with  the e-Invoice. 

If the e-Invoice is returned unvalidated, an error message will be displayed. The Supplier is required to correct the error and submit it for validation again once the errors have been corrected. 

Figure 2.5 – e-Invoice validation workflow (MyInvois Portal) 

2.3.4 Step 3 – Notification 

Once the e-Invoice has been validated, IRBM will notify both the Supplier  and Buyer via the MyInvois Portal. An e-mail will be sent for this  notification. Notifications include invoice clearance and Buyer rejection  requests.  

Figure 2.6 – e-Invoice notification workflow (MyInvois Portal) 

2.3.5 Step 4 – Sharing of e-Invoice / visual representation  

Upon validation of the e-Invoice, the Supplier is obliged to share the  validated e-Invoice with the Buyer. The visual representation of the  e-Invoice generated from the MyInvois Portal will include a QR code, which can be used to validate the existence and status of the e-Invoice via the MyInvois Portal. 

However, the IRBM acknowledges that there may be practical challenges  in sharing the validated e-Invoice with the Buyer. Therefore, until further  notice, the IRBM provides a concession allowing the Supplier to share  either the validated e-Invoice or a visual representation of the validated  e-Invoice with the Buyer.

Figure 2.7 – Sharing of e-Invoice workflow (MyInvois Portal) 

2.3.6 Step 5, 6 and 7 – Rejection or Cancellation 

Once the e-Invoice has been validated by IRBM, Supplier and Buyer are  allowed to cancel or reject the said e-Invoice, within a stipulated time. 

1. Buyer to request rejection of the e-Invoice 

a. If the e-Invoice contains errors, the Buyer is able to request  rejection of the e-Invoice within 72 hours from the time of  validation via the MyInvois Portal. 

b. The rejection request should specify the reason, which can include  erroneous information (e.g., SST number, business registration  number, any business-related information, etc.). 

c. Upon the Buyer initiating the rejection request, a notification will  be sent to the Supplier. 

d. If the Supplier is satisfied / agreeable to the reason provided, the  Supplier may proceed to cancel the said e-Invoice within 72 hours  from the time of validation. 

e. If the Supplier did not accept the request for rejection initiated by  the Buyer (or did not proceed to cancel the said e-Invoice), no  cancellation would be allowed after the 72 hours have elapsed.  Any amendment thereon would require a new e-Invoice (e.g.,  credit note, debit note or refund note e-Invoice) to be issued. 

2. Supplier to perform cancellation of e-Invoice 

a. If the e-Invoice contains errors or was erroneously issued, the  Supplier can cancel the e-Invoice within 72 hours from the time of  the validation via MyInvois Portal. 

b. Cancellation requests must also be accompanied by justifications. c. Upon cancellation, a notification will be sent to the Buyer. 

If the e-Invoice is not rejected or cancelled within 72 hours, no cancellation  would be allowed. Any subsequent adjustments would have to be made by issuing a new e-Invoice (e.g., credit note, debit note or refund note  e-Invoice). 

Kindly note that the 72-hour timeframe for Buyers to raise rejection  request and/or Supplier to cancel the e-Invoice is provided for the  convenience of Supplier and Buyer. In the event the Supplier does not  want to utilise the cancellation / rejection function, any adjustment can still  be done via issuance of credit note / debit note / refund note e-Invoice.

Figure 2.8 – e-Invoice rejection and cancellation workflow (MyInvois Portal) 

Example 3 (using MyInvois Portal, Step 1 to Step 7) 

Stationery Hub Sdn. Bhd. (Supplier) is an MSME that supplies  stationeries. Stationery Hub Sdn. Bhd. generates an e-Invoice for the sale  of 50 stationery items, purchased by Mrs. Kim (Buyer), on the MyInvois  Portal and submits the e-Invoice for validation. Upon validation by IRBM,  both Stationery Hub Sdn. Bhd. and Mrs. Kim are notified. Mrs. Kim  receives the validated e-Invoice from Stationery Hub Sdn. Bhd. Mrs. Kim  is responsible to check the e-Invoice for accuracy and completeness (e.g.,  TIN, price, product quantity, etc). In the event the e-Invoice contains  errors, Mrs. Kim is able to request a rejection of the e-Invoice via the  MyInvois Portal within 72 hours from the time of validation. 

2.3.7 Step 8 – Storing e-Invoices 

All validated e-Invoices will be stored in IRBM’s database. Notwithstanding the storage of e-Invoice by IRBM, taxpayers are  reminded to retain sufficient records and documentation in relation to the  transaction.

Figure 2.9 – Storing of e-Invoice workflow (MyInvois Portal) 

2.3.8 Step 9 – Reporting and Dashboard Services for Taxpayers 

Through the MyInvois Portal, both Supplier and Buyer will have the option  to request and retrieve e-Invoice. MyInvois Portal provides essential  invoice details such as the invoice date, amount, invoice status, and other  relevant information submitted to IRBM, in the format of: 

1. XML / JSON, either one-by-one or in package 

2. Metadata 

3. Grid 

4. PDF file 

Figure 2.10 – Reporting & Dashboards workflow (MyInvois Portal)

For e-Invoices generated through MyInvois Portal, taxpayers would be  able to request and retrieve the said e-Invoices via MyInvois Portal. 

2.4 e-Invoice model via API 

API allows taxpayers to submit e-Invoices directly to IRBM. Methods to transmit e-Invoice via API include: 

i. Direct integration of taxpayers’ ERP system with MyInvois System. ii. Through Peppol service providers. 

iii. Through non-Peppol technology providers. 

The API integration and configuration guide along with the API endpoints are  included in the SDK. 

The e-Invoice structure has been specifically designed to cater to B2B, B2G and  B2C transactions to ease e-Invoice procedures for businesses and individuals. The following formats will be supported for e-Invoice submission, while adhering  to the data structure of Universal Business Language Version 2.1 (UBL2.1): 

1. Extensible Markup Language (XML): XML is defined as a simple text-based format for representing structured information. It is one of the  most widely used formats for sharing field structured information today. The  syntax rules for XML are strict. It will not process files that contain errors and  error messages will be sent to inform that rectification is required. Almost all  XML documents can be processed reliably by computer software. 

2. JavaScript Object Notation (JSON): JSON is a lightweight text-based data  interchange format that is simpler to read and write as compared to XML.  Though it is derived from a subset of JavaScript, it is language independent.  Therefore, the code for generating and parsing JSON data can be written in  any other programming language.

There are 55 data fields that are required to issue an e-Invoice. These fields are  grouped into eight (8) categories: 

1. Address 

2. Business Details 

3. Contact Number 

4. Invoice Details 

5. Parties 

6. Party Details 

7. Payment Info 

8. Products / Services 

In addition, for specific circumstances, an annex will be required to be submitted  as part of the e-Invoice to IRBM. For the list of data fields, refer to Appendix 1. 

The summary of the e-Invoice model flow via API is diagrammatically depicted  in Figure 2.11. 

Figure 2.11 – e-Invoice model workflow via API

2.4.1 Pre-Submission – e-Invoice Submission Requirements

2.4.1.1 Digital Certificate 

A digital certificate is a document (i.e., .cer or .pfx) that helps to verify the  identity of the issuer issuing the e-Invoice. The digital signature will verify  that the submitted e-Invoice originates from a specific taxpayer. The  hashed value of the digital signature will be part of the e-Invoice API  submission request body. 

2.4.1.2 e-Invoice Preparation 

Taxpayers need to configure their systems or engage a technology provider to assist them in generating e-Invoices in the required XML or  JSON format with mandatory and optional fields in accordance with the  defined structure.  

2.4.2 Step 1 – Submission 

When a sale or transaction is concluded (including e-Invoice  adjustments), the Supplier or technology provider creates an e-Invoice in  accordance with the defined UBL2.1 structure in XML / JSON format, and  submits it to IRBM via API for validation. Supplier is to ensure the  accuracy of the information included in the e-Invoice that is submitted to  IRBM for validation, to the extent possible. 

Figure 2.12 – e-Invoice submission workflow (API)

2.4.3 Step 2 – e-Invoice Validation 

Once validated by the MyInvois System (which is done in near real-time),  the Supplier or technology provider (if Supplier utilises a technology  provider) will receive an API response which contains the following: 

(a) the IRBM Unique Identifier Number from IRBM; 

(b) date and time of validation; and  

(c) information to form validation link (please refer to Get Recent  Documents / Get Document / Get Documents Details in the SDK for  guidance), 

via API.  

The IRBM Unique Identifier Number will allow traceability by IRBM and  will reduce instances of tampering with the e-Invoice. 

If errors are detected during validation, an API error response will be  shown. Accordingly, API response will be provided upon successful  validation. Once the e-Invoice is successfully validated, notification will be  sent to the Supplier and Buyer. 

Figure 2.13 – e-Invoice validation workflow (API) 

2.4.4 Step 3 – Sharing of e-Invoice / visual representation  

Upon validation of the e-Invoice, the Supplier is obliged to share the  validated e-Invoice with the Buyer. In the event the Supplier shares the  visual representation of the e-Invoice to the Buyer, the Supplier is required  to ensure that the QR code is embedded accordingly, which the QR code can be used to validate the existence and status of the e-Invoice via  MyInvois Portal. 

However, the IRBM acknowledges that there may be practical challenges  in sharing the validated e-Invoice with the Buyer. Therefore, until further  notice, the IRBM provides a concession allowing the Supplier to share  either the validated e-Invoice or a visual representation of the validated  e-Invoice with the Buyer.  

Figure 2.14 – Sharing of e-Invoice workflow (API) 

2.4.5 Step 4, 5 and 6 – Rejection and Cancellation 

Once the e-Invoice has been validated by IRBM, Supplier and Buyer are  allowed to cancel or reject the said e-Invoice, within a stipulated time. 

1. Buyer to request rejection of the e-Invoice via API 

a. If the e-Invoice contains errors, the Buyer is able to request a  rejection of the e-Invoice within 72 hours from the time of  validation via API.  

b. The rejection request in the request body of the API should specify  the unique identifier of the e-Invoice and the reason for rejection,  which can include erroneous information (e.g., SST number,  business registration number, any business-related information, etc.).

c. Upon the Buyer initiating the rejection request, a notification will  be sent to the Supplier. 

d. If the Supplier is satisfied / agreeable to the reason provided, the  Supplier may proceed to cancel the said e-Invoice within 72 hours  from the time of validation. 

If the Supplier did not accept the request for rejection initiated by  the Buyer (or did not proceed to cancel the said e-Invoice), no  cancellation would be allowed after the 72 hours have elapsed.  Any amendment thereon would require a new e-Invoice (e.g.,  credit note, debit note or refund note e-Invoice) to be issued.  

2. Supplier to perform cancellation of e-Invoice via API 

a. If the e-Invoice contains errors or was erroneously issued, the  Supplier can cancel the e-Invoice within 72 hours from the time of  the validation via API where the request body of the API must  contain the unique identifier of the e-Invoice. 

b. Upon cancellation, a notification will be sent to the Buyer. The  Supplier would need to issue a new e-Invoice in accordance with  Step 1 above, if applicable. 

If the e-Invoice is not rejected or cancelled within 72 hours, no cancellation  would be allowed. Any subsequent adjustments would have to be made  by issuing a new e-Invoice (e.g., credit note, debit note or refund note  e-Invoice). 

Kindly note that the 72-hour timeframe for Buyers to raise rejection  request and/or Supplier to cancel the e-Invoice is provided for the  convenience of Supplier and Buyer. In the event the Supplier does not  want to utilise the cancellation / rejection function, any adjustment can still  be done via issuance of credit note / debit note / refund note e-Invoice.

Figure 2.15 – e-Invoice rejection and cancellation workflow (API) 

Example 4 (using API, Step 1 to Step 6) 

Hebat Group (Buyer) obtains supplies of various fresh produce for all its  hypermarket outlets directly from Fresh Food Hub (Supplier), once a  week. For each sale made, Fresh Food Hub uses its own ERP system to  generate and issue e-Invoices via API in XML / JSON format. Fresh Food  Hub will be required to attach its digital signature on the e-Invoice to  validate that the invoice originated from Fresh Food Hub. Upon validation  of the e-Invoice by IRBM, Fresh Food Hub embeds a QR code which  contains a validation link to the visual representation of the validated e-Invoice and shares it with Hebat Group. 

Upon receiving the e-Invoice, Hebat Group’s Finance Manager detected  errors on the quantity and pricing for certain products. Within 72 hours,  Hebat Group requested for a rejection of the said e-Invoice from Fresh  Food Hub via MyInvois Portal or API (depending on the e-Invoice model  adopted by Hebat Group) and included an explanation on the errors  detected. Upon requesting for a rejection of the e-Invoice, a notification was sent by IRBM to both Fresh Food Hub and Hebat Group. Fresh Food  Hub contacted Hebat Group’s Finance Manager immediately to discuss  on the errors and once the errors have been verified, Fresh Food Hub  reissues a revised e-Invoice (and the process of issuing  e-Invoice is repeated). 

2.4.6 Step 7 – Storing e-Invoices 

All validated e-Invoices will be stored in IRBM’s database.  Notwithstanding the storage of the e-Invoice, taxpayers are reminded to  retain sufficient records and documentation in relation to the transaction.

Figure 2.16 – Storing of e-Invoice workflow (API) 

2.4.7 Step 8 – Reporting and Dashboards Services for Taxpayer 

Through API integration, both Supplier and Buyer will have the option to  request and retrieve e-Invoice, which can be seamlessly displayed on their  respective systems. The API integration enables access to essential  e-Invoice details such as the invoice date, amount, invoice status, and  other relevant information submitted to IRBM, in the format of: 

1. XML / JSON, either one-by-one or in package  

2. Metadata 

Figure 2.17 depicts the integration to enable Suppliers and Buyers to  efficiently retrieve and utilise e-Invoice within their own systems, thus streamlining processes and enhancing transparency in e-Invoice  management.

Figure 2.17 – Reporting and Dashboards workflow (API) 

2.5 Validation  

2.5.1 The e-Invoice submitted by the taxpayers will undergo a series of  validations within the MyInvois System, ensuring adherence to the data  field requirements, formats and standards as stipulated by the IRBM. 

2.5.2 The following is the list of e-Invoice statuses:  

i. Submitted: The e-Invoice has been successfully transmitted to  MyInvois System and passed the immediate validations, including  e-Invoice structure and core field validations. 

ii. Valid: The e-Invoice has passed all the immediate and background  validations to meet all the data field requirements, formats and  standards as defined by the IRBM.  

iii. Invalid: The e-Invoice has failed one or more validation checks due  to incorrect data field requirements, formats or standards as defined  by the IRBM.

iv. Cancelled: An e-Invoice can only be cancelled by the Supplier within  72 hours of its validation date and time. A cancelled e-Invoice is no  longer valid, and if necessary, a new e-Invoice is required to be  issued. 

2.5.3 e-Invoice validation involves a set of rules used to ensure that submitted  documents meet specific requirements. The document validation rules  are outlined below: 

Table 2.2 – List of document validation rules 

For details of the document validation rules, please refer to Validations in  the SDK. 

2.5.4 In circumstances where the MyInvois System experiences disruptions,  system failures, unforeseen malfunctions or service outages (based on  MyInvois System’s performance records), IRBM acknowledges that such  occurrences will disrupt taxpayers’ attempt to transmit the e-Invoices for  IRBM’s validation in a timely manner. 

In cases where the MyInvois System is down due to maintenance or  technical issues, and taxpayers are able to demonstrate their evidence of  their e-Invoice compliance efforts, the Director General of Inland Revenue  will evaluate this on a case-to-case basis. If the justifications are valid, the  Director General will not take action against the taxpayers for their inability  to comply with the e-Invoice transmission and validation requirements  during such period.

2.6 Sharing of e-Invoice information between IRBM and Royal Malaysian  Customs Department (RMCD) 

2.6.1 e-Invoice requirements as stipulated in Appendix 1 have taken into  account the required particulars of the key tax legislation, including the  Income Tax Act 1967, Labuan Business Activity Tax Act 1990, Petroleum  (Income Tax) Act 1967, Sales Tax Act 2018 and Service Tax Act 2018. 

2.6.2 Pursuant to Section 138(4)(aa) of the Income Tax Act 1967, e-Invoice  information submitted by taxpayers to the MyInvois System will be shared  with the RMCD. 

2.6.3 For clarity, taxpayers are allowed to adopt any visual representation  format for e-Invoice as per current practice. In this regard, taxpayers are  advised to include any other particulars as may be required under the  applicable laws, rules and regulations such as Sales Tax Act 2018 and  Service Tax Act 2018. 

2.6.4 For example, if the taxpayer is registered for service tax and the visual  representation of the e-Invoice contains the necessary particulars required under Service Tax Regulations 2018, the taxpayer can use the  same visual representation for service tax purposes. 

3.0 DATA SECURITY AND PRIVACY MONITORING BY IRBM 

MyInvois System is designed by IRBM with the necessary Network & Security  monitoring tools to ensure data security and privacy. Hence, these are some of the  key steps that will be taken in monitoring the e-Invoice data security and privacy: 

1. IRBM will assess the data protection needs. Before IRBM starts monitoring and  auditing the e-Invoice data security and privacy, IRBM will identify the type of  data that IRBM collects, processes, stores, and shares through the MyInvois System. By having that process in place, IRBM will understand the legal and  contractual obligations that apply to the data, such as data privacy laws or  specific industry standards. From the data protection needs, IRBM can define  the data security and privacy policies and objectives. 

2. Implementation of data protection controls in order to protect the e-Invoice from  unauthorised access, modification, loss or disclosure. IRBM will implement  appropriate technical and organisational controls. These may include encryption,  authentication, access control, backup, firewall, antivirus, and logging of access. 

3. Monitoring and auditing data protection performance and incidents. This can be  done by benchmarking the performance against the objectives and industry best  practices and reporting, investigating, resolving, and learning from any data  breaches, errors, complaints, or violations that may affect the e-Invoice. 

4. Based on the results of the monitoring and auditing activities, IRBM will continue  to review and improve data protection practices to address any gaps,  weaknesses, or opportunities for improvement in the data protection policies,  controls, performance, or incidents.

4.0 ASSESSING READINESS OF E-INVOICE 

To ensure that businesses are ready for the implementation of e-Invoice in the  upcoming months, here are a few key steps that can be carried out to assess readiness and standardisation: 

1. Allocate and equip personnel with the necessary capabilities to adopt and oversee the implementation of e-Invoice; 

2. Determine availability of data sources and structure, current IT capabilities to  support system readiness and processes to comply to e-Invoice requirements  and obligations; and 

3. Review current processes in issuing transaction documents (i.e., invoice, debit  note, credit note, refund note).

APPENDIX 1 – LIST OF REQUIRED FIELDS FOR E-INVOICE 

Appendix Table 1 sets out a list of required fields for an e-Invoice. Taxpayers are free to  include additional fields, where required.

Appendix Table 1 – List of data fields required to issue an e-Invoice

APPENDIX 2 – LIST OF MANDATORY AND OPTIONAL FIELDS UNDER ANNEXURE TO THE E-INVOICE

Appendix Table 2 – List of mandatory and optional fields under Annexure

Note: The field requirements for an annex to the e-Invoice may be updated from time to time.

APPENDIX 3 – LIST OF INTERNATIONAL ORGANISATIONS 

1. Alliance for Financial Inclusion (AFI) 

2. Asia-Pacific Broadcasting Union (ABU) 

3. Asia-Pacific Institute for Broadcasting Development (AIBD) 

4. Asian Development Bank (ADB) 

i. Credit Guarantee & Investment Facility (CGIF) 

5. Asian International Arbitration Centre in Kuala Lumpur (AIAC) – formerly known  as Kuala Lumpur Regional Centre for Arbitration (KLRCA) 

6. Asian Football Confederation (AFC) 

7. ASEAN Football Federation (AFF) 

8. Association of Natural Rubber Producing Countries (ANRPC) 9. Association of Southeast Asian Nations (ASEAN) 

10. Badminton World Federation (BWF) 

11. Centre for Agriculture and Bioscience International (CABI) 

12. Centre for Indonesia–Malaysia–Thailand (CIMT) 

13. Intergovernmental Organization for Marketing Information and Technical Advisory  Services for Fishery Products in the Asia and Pacific Region (INFOFISH) 14. International Centre for Living Aquatic Resources Management (ICLARM– WorldFish) 

15. International Committee of the Red Cross (ICRC) 

16. International Federation of Red Cross and Red Crescent Societies (IFRC) 17. International Islamic Liquidity Management Corporation (IILM) 18. International Labour Organization (ILO) 

19. International Planned Parenthood Federation (IPPF) 

20. International Plant Genetic Resources Institute (IPGRI) 

21. International Tropical Fruits Network (TFNet) 

22. Islamic Corporation for the Development of the Private Sector (ICD) 23. Islamic Development Bank (IsDB) 

24. Islamic Financial Services Board (IFSB) 

25. Japan International Cooperation Agency (JICA)

26. Malaysia–Thailand Joint Authority (MTJA) 

27. Malaysian–American Commission on Educational Exchange (MACEE) 28. The Asian Foundation (TAF) 

29. Regional Centre for Research and Training in Tropical Diseases and Nutrition  (RTTD) 

30. Southeast Asian Ministers of Education Organization Regional Centre for Special  Education (SEAMEO SEN) 

31. United Nations Children’s Fund (UNICEF) 

32. United Nations Development Programme (UNDP) 

33. United Nations Development Programme Global Shared Services Centre (UNDP  GSSC) 

34. United Nations Educational, Scientific and Cultural Organization (UNESCO) 35. United Nations Population Fund (UNFPA) 

36. United Nations University – International Institute for Global Health (UNU–IIGH) 37. World Bank Group (WBG) 

i. International Bank for Reconstruction and Development (IBRD) ii. International Development Association (IDA) 

iii. International Finance Corporation (IFC) 

iv. Multilateral Investment Guarantee Agency (MIGA) 

v. International Centre for Settlement of Investment Disputes (ICSID) 38. World Food Programme (WFP) 

39. World Health Organization (WHO) 

40. World Health Organization Global Service Centre (WHO GSC) 41. World Organization of the Scout Movement (WOSM)

GLOSSARY

Glossary Table 1