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a compilation of official LHDN industry specific faqs on e invoicing in malaysia

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.

official workflow of e-invoicing from LHDN guidelines
Applies to most, but not all.

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

picture of pills and medicine to show it is the section for e invoicingguidelines for hospitals and clinics in malaysia
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

picture of construction site to show section for e invoicing guidelines for construction industry in malaysia
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

picture of wifi signal to show it is the section for e invoicing guidelines for telecommunication industry in malaysia
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

picture of offshore oil rig signal to show it is the section for e invoicing guidelines for oil gas industry in malaysia
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

picture of online business sign to show it is the section for e invoicing guidelines for ecommerce industry in malaysia
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.

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