37 Industry-Specific FAQs On e-Invoicing In Malaysia

Aside from an overview of general e-Invoicing guidelines, business owners, consultants and decision makers will no doubt have questions on how certain industries and business activities are affected.

LHDN’s indutry-specific FAQs are awkwardly spread across separate documents, and we feel the text inside could be a tad less wordy. To help readers, we’ve consolidated the FAQs and edited them for clarity, bringing you a total of 37 clarifications on e-Invoicing guidelines across these five industries:

• Healthcare
• Construction
• Telecommunication
• Oil & Gas, and 
• eCommerce  

Readers who prefer primary sources are of course welcome to access the official LHDN documents here.

Otherwise, let’s begin.

Healthcare

Question 1

Can hospitals continue its current invoicing process for staff medical expenses upon implementing e-Invoicing?

Answer: Yes.

Question 2

Can hospitals still issue separate bills for insurance-covered charges and patient-covered charges upon implementing e-Invoice?

Answer: Yes, though said bills would have to be in the form of an e-Invoice.

Question 3

When should a hospital issue an e-Invoice if providing proforma bills to insurance companies for Final Guarantee Letter requests?

Answer: Follow current billing arrangements – issue a draft/proforma invoices for FGL requests as needed before submitting the e-Invoice to LHDN after finalising billing arrangements.

Question 4

Will the current invoicing process for consultant fees remain unchanged?

Answer: Yes.

Question 5

Who is responsible for issuing e-Invoices in service contract scenarios, either directly with individual doctors or through a representing company?

Answer: Generally, individual doctors or representing companies should issue e-Invoices based on contract type.

Question 6

Is an e-invoice required for space rental (e.g., cafes) within the hospital compound?

Answer: Yes.

Question 7

Who is listed as Buyer if parents / guardians pay medical expenses for children >18?

Answer: The parent / guardian or relevant parties.

Question 8

How to issue e-Invoices for patients referred to sister companies / private hospitals?

Answer: Follow current billing arrangements.

Question 9

Can the hospital issue consolidated e-invoices for self-paying patients who don’t require individual e-Invoices?

Answer: Yes.

Question 10

What is the e-Invoice treatment for hospital admission deposits?

Answer: Not needed for refundable deposits and needed for non-refundable ones.

Question 11

What’s the e-Invoice treatment for transactions with multiple payors?

Answer: Hospitals are allowed to follow current billing arrangements.

Question 12

Must consultants implement e-Invoice in Phase 1 if the hospital’s annual turnover reaches RM100 million?

Answer: They are considered separate taxpayers and it depends on their respective revenue thresholds.

Question 13

Should the hospital submit summary or detailed bills during e-Invoice submissions?

Answer: For e-invoices, submit detailed bills.

Construction

Question 1

Are e-Invoices needed for charges to sub-contractors, including penalties?

Answer: Yes.

Question 2

How must contractors handle e-Invoices for progress claims on property construction?

Answer: Contractors must issue e-Invoices for progress claims but they can issue the e-Invoice upon obtaining the certificate if certification of work done is required.

Question 3

Will the main contractor’s billing process for purchasing materials on behalf of the owner stay the same?

Answer: Yes, but they must issue bills in the form of e-Invoices.

Question 4

If a company begins e-Invoice implementation in Phase 1, do they issue e-Invoices to related companies when selling construction materials?

Answer: Yes, and consolidated e-Invoices are not allowed for such transactions.

Telecommunication

Question 1

Will telecommunication service providers continue their current billing arrangement?

Answer: Yes, they can either:

1. Adjust previous bills, or 
2. Issue credit/debit/refund note e-Invoices

Question 2

Will current invoicing for selling prepaid plans stay the same?

Answer: Yes.

Question 3

What’s the e-Invoice treatment for premise rental by telco providers?

Answer: Two possible outcomes:

1. Landlord issues e-Invoice if conducting business; 
2. Teleco provider issues self-billed e-Invoices otherwise.

Question 4

Who issues e-Invoices to customers for add-on services via telco service providers?

Answer:

• Local vendors issue e-Invoices
• Customers issue self-billed e-Invoices for foreign vendors 
• Telco service providers must issue e-Invoices for platform fee charges.

Oil & Gas

Question 1

Whose Tax Identification Number is used as Supplier when a contractor of a Production Sharing Contract sells crude oil to a buyer?

Answer: The contractor’s TIN, along with corresponding contractor’s details.

Question 2

Whose TIN is used as Buyer for costs incurred for petroleum operations?

Answer:

• For joint costs: PSC operator’s TIN.
• For sole costs: Contractor’s TIN.

Question 3

If several PSCs are in the same area, which TIN is used as Supplier and Buyer?

Answer:

• Supplier: Contractor’s TIN.
• Buyer: PSC operator’s TIN for joint costs and Contractor’s TIN for sole costs.

Question 4

Are e-Invoices needed for inter-ledger transactions between PSCs and operators?

Answer: No, until further notice.

Question 5

What if a contractor of a PSC concludes a sale of crude oil via an agent?

Answer: Contractor issues e-Invoice to agent, who then issues e-Invoice to buyer.

Question 6

Can a PSC operator issue e-Invoices on behalf of contractors under the Upstream Gas Sales Agreement?

Answer: Yes, with contractor’s details as Supplier.

Question 7

What is the e-Invoice treatment for supplementary payment?

Answer: True up or down via issuance of debit or credit note e-Invoice.

Question 8

Are cash call and joint interest billing (JIB) in scope for e-Invoice?

Answer: No.

eCommerce

Question 1

Who issues e-Invoices to consumers in transactions via a platform?

Answer: The e-commerce platform provider.

Question 2

Who issues e-Invoices to record income by merchants or service providers?

Answer: The e-commerce platform provider.

Question 3

What’s the e-Invoice treatment for platform use charges by platform providers?

Answer: E-commerce platform providers must issue e-Invoices for platform use charges.

Question 4

Which Tax Identification Number is used as Supplier if merchant is a foreign entity?

Answer: The general TIN “EI00000000030” can be used in a self-billed e-Invoice.

Question 5

Can e-commerce platform providers issue consolidated e-Invoices for income generated by merchant e-commerce transactions?

Answer: No.

Question 6

When should an e-Invoice be issued by e-commerce platform providers to record income generated by merchants?

Answer: E-commerce platform providers can issue draft / proforma invoices if necessary, but only the final e-Invoice needs to be submitted for validation.

Question 7

What’s the e-Invoice treatment for refunds for returned goods?

Answer: E-commerce platform providers issue refund note e-Invoices.

Question 8

Can retailers include e-commerce transactions in the same consolidated e-Invoice as brick-and-mortar store transactions?

Answer: No, as different transaction flow and classification could cause potential reconciliation issues.

Let MISHU assist your e-Invoicing transition

Got a question on e-Invoicing that even the mega FAQ above didn’t address? Get in touch with our team and we’ll do our best to help!