Ever notice how the Inland Revenue Board of Malaysia (IRBM) loves to drop the latest updates on a Friday night? It always means overtime for us to catch up!
Based on the media release published on 26 July 2024, the IRBM has announced flexibility for taxpayers to issue consolidated e-Invoices for six months starting from the mandatory e-Invoice implementation date (e.g. 1 August 2024). This relaxation period is intended to provide taxpayers with sufficient time to fully implement e-Invoicing.
During this period, businesses are allowed to issue consolidated e-invoices for all transactions, including self-billed e-invoices.
However, it’s important to note that the mandatory implementation of e-invoicing hasn’t been postponed. Instead, it is a temporary relaxation to ease the transition for taxpayers.
Important Considerations
1. This is a temporary measure
The e-Invoicing implementation is not delayed. The recent update simply allows businesses more flexibility in how they submit invoices. We’re now allowed to issue consolidated e-invoices for all transactions, regardless of whether the buyer requests an e-invoice or not. While this six-month period offers some flexibility, it’s essential to remember that businesses are still required to keep a copy of the receipts issued when submitting consolidated e-Invoices to the IRBM within 7 days after the month-end for all aggregated transactions.
2. Customer invoicing requirements
During this relaxation period, businesses don’t have to send individual e-invoices to each customer. However, customers still need to receive a regular invoice, bill, or receipt for their purchases.
3. Consolidation of e-Invoices for all industries
During this period, the seven industries that are not allowed to issue consolidated e-Invoices are now permitted to do so. Furthermore, all self-billed circumstances as outlined in the Specific Guideline, including importation of goods and services, are allowed to issue consolidated e-Invoice. This will help all taxpayers in every industry ease the transition to e-invoicing implementation.
4. Penalties for non-compliance
Remember, failing to adhere to the consolidated e-invoice rules can result in penalties. While there’s some flexibility, it’s important to comply with the regulations by consolidating and submitting your invoices to the IRBM on time.
This image presents the latest 6-month relaxation period from the mandatory e-invoicing implementation date to issue consolidated e-invoices for all transactions, categorized by business annual revenue.
Taxpayers with an annual turnover or revenue of more than RM 100 mil: August 2024 to January 2025
Taxpayers with an annual turnover or revenue of more than RM 25 mil and up to RM 100 mil: January 2025 to June 2025
All other taxpayers: July 2025 to December 2025
When Consolidated e-Invoice Meets Self-Billed e-Invoice: The Birth of the Consolidated Self-Billed e-Invoice
What is Consolidated Self-Billed e-Invoice?
Self-billing refers to a situation where the buyer, rather than the seller, issues an invoice for proof of expense. Meanwhile, consolidated e-invoices allow businesses to group multiple transactions into a single e-invoice. When a buyer issues a consolidated self-billed e-invoice, they are essentially combining the principles of self-billing with consolidation. The buyer issues a single e-invoice summarizing multiple transactions that they themselves initiated (i.e. self-billed) over a specific period, instead of generating individual self-billed e-invoices for each transaction.
During this six-month relaxation period, businesses are allowed to issue consolidated e-invoices, including the self-billed ones.
The timing of issuance for consolidated self-billed e-invoices and consolidated e-invoices is the same: they must be submitted monthly within 7 calendar days after the end of the month.
Additionally, there’s positive news! The IRBM will not undertake any legal action during this six-month relaxation period on non-compliance of the e-invoice requirements, provided that taxpayers comply with the requirement to issue consolidated e-invoices.
(A sample visual representation of a consolidated self-billed e-Invoice)
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