1. Has there been any change to the mandatory implementation date for taxpayers with an annual turnover or revenue exceeding RM100 million due to the release of Income Tax (Issuance of Electronic Invoice) Rules 2024 [P.U. (A) 265] on 30 September 2024? If so, what is the revised mandatory implementation date for these taxpayers?
The Income Tax (Issuance of Electronic Invoice) Rules 2024 [P.U. (A) 265] has been gazetted effective from 1 October 2024. The rules are issued in accordance with the power conferred to Minister to prescribe a person to issue an eInvoice and the particulars to be included in the e-Invoice.
The prescribed mandatory implementation date of 1 October 2024 for taxpayers with an annual turnover or revenue of more than RM100 million specifically relates to the period when enforcement actions for non-compliance may be initiated by the IRBM against such taxpayers. In other words, any penalty for non-compliance, should they arise, will only be imposed starting from 1 October 2024.
The mandatory implementation date as outlined in Section 1.5 of the e Invoice Guideline remains unchanged.

2.Where the imported goods are purchased under one foreign supplier’s invoice but imported into Malaysia via multiple shipments (with different RMCD’s clearance dates), when will the Malaysian buyer be required to issue self-billed e-Invoice?
Where there are multiple import clearances under the same invoice from the foreign supplier, the timing for the issuance of the self-billed e-Invoice are as follows:
a) If the foreign supplier’s invoice is issued by the time the first import shipment clearance is obtained
As an example, Company ABC Sdn Bhd has purchased 4,000 units of machinery from DEF Ltd in China. The machineries will be imported into Malaysia via four separate shipments. The issuance of self-billed e-Invoice shall be as follows:
The Malaysian buyer is required to issue self-billed e-Invoice based on the foreign supplier’s invoice as per the timing of issuance outlined under Section 10.4.8 of the e-Invoice Specific Guideline (i.e., latest by the end of the month following the month of RMCD’s clearance is obtained). The Malaysian buyer is required to input the customs form reference number (e.g., Customs Form No.1) in the self-billed e-Invoice.
No self-billed e-Invoice is required to be issued for the subsequent shipments for goods that are included within the same foreign supplier’s invoice.

b) If the foreign supplier’s invoice is issued after the first RMCD’s clearance
- The Malaysian buyer is required to issue:
- Self-billed e-Invoice for each import shipment, based on the amount declared to RMCD. The self-billed e-Invoice is required to be issued as per the timing of issuance outlined under Section 10.4.8 of the e-Invoice Specific Guideline (i.e., latest by the end of the month following the month of each RMCD’s clearance is obtained) and the relevant customs form reference number (e.g., Customs Form No. 1) is required to be input in each self-billed e-Invoice; and
- a final self-billed e-Invoice upon issuance of the foreign supplier’s invoice. The final self-billed e-Invoice is required to be issued by the next RMCD’s clearance (timing of issuance is outlined under Section 10.4.8 of the e-Invoice Specific Guideline i.e., latest by the end of the month following the month of RMCD’s clearance is obtained) and the relevant customs form reference number (e.g., Customs Form No. 1) is required to be input in the said self-billed e-Invoice.
- No self-billed e-Invoice is required to be issued for the subsequent shipments of goods that are included within the same foreign supplier’s invoice.
- As an example, Company ABC Sdn Bhd has purchased 4,000 units of machinery from DEF Ltd in China. The machineries will be imported into Malaysia via four separate shipments. The issuance of self-billed e-Invoice shall be as follows:

c) If the foreign supplier’s invoice is issued after the final import shipment
- The Malaysian buyer is required to issue:
- self-billed e-Invoice for each import shipment, based on the amount declared to RMCD. The self-billed e-Invoice is required to be issued as per the timing of issuance outlined under Section 10.4.8 of the e-Invoice Specific Guideline (i.e., latest by the end of the month following the month of each RMCD’s clearance is obtained) and the relevant customs form reference number (e.g., Customs Form No. 1) is required to be input in each self-billed e-Invoice; and
- a final self-billed e-Invoice upon the issuance of foreign supplier’s invoice, if the total amount in the foreign supplier’s invoice is different from the total self-billed e-Invoices. The final self-billed e-Invoice is required to be issued latest by the end of the month following the month of the foreign supplier’s invoice.
- As an example, Company ABC Sdn Bhd has purchased 4,000 units of machinery from DEF Ltd in China. The machineries will be imported into Malaysia via four separate shipments. The issuance of self-billed e-Invoice shall be as follows:

3. If I purchase goods from foreign supplier but the goods are delivered from a bonded warehouse / Free Zone, do I need to include the customs form reference number in the selfbilled e-Invoice issued?
Where the goods are delivered by the Foreign Supplier from the bonded warehouse / Free Zone to the Malaysian buyer located in a PCA, the Malaysian buyer is required to input the customs form reference number (e.g., Customs Form No. 1 or No. 9) in the self-billed e-Invoice. Kindly refer to the illustration below for further clarity

4. If I am located in a bonded warehouse and purchase goods from a foreign supplier, and the said goods are subsequently sold to a Malaysian buyer, what are the e-Invoice treatments?
In a scenario where Malaysian Buyer #1 located in a bonded warehouse purchases goods from
a Foreign Supplier and subsequently sell the goods to Malaysian Buyer #2, the e-Invoice treatments are as follows:
a) Malaysian Buyer #1 to issue a self-billed e-Invoice for the goods purchased from the Foreign Supplier. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. As such, the Malaysian Buyer #1 may input the customs form reference number (e.g., Customs Form No. 8) at their discretion. Kindly refer to Step 4 of the illustration below for further clarity.
b) Malaysian Buyer #1 to issue an e-Invoice for the goods sold to Malaysian Buyer #2. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. Kindly refer to Step 8 of the illustration below for further clarity

5. If I purchase goods from a foreign supplier (where the goods are stored in bonded warehouse / Free Zone) and I subsequently sell the goods to another Malaysian buyer (i.e., MY Buyer #2), how should the e-Invoice and self-billed e-Invoice be issued?
In a scenario where Malaysia Buyer #1 purchases goods from a Foreign Supplier who stores the goods in bonded warehouse / Free Zone and Malaysian Buyer #1 subsequently sells the said goods to Malaysian Buyer #2, the e-Invoice treatments are as follows:
a) Malaysian Buyer #1 to issue a self-billed e-Invoice for the goods purchased from the Foreign Supplier. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. As such, the Malaysian Buyer #1 may input the customs form reference number (e.g., Customs Form No. 8) at their discretion. Kindly refer to Step 5 of the illustration below for further clarity.
b) Malaysian Buyer #1 to issue an e-Invoice for the goods sold to Malaysian Buyer #2. The “Reference Number of Customs Form No.1, 9, etc.” field is optional. Kindly refer to Step 9 of the illustration below for further clarity.

6. I purchase goods from a foreign supplier and subsequently sell the goods to other Malaysian buyers. However, I instruct the foreign supplier to directly deliver the goods to the other Malaysian buyers. How should the e-Invoice and self-billed e-Invoice be issued?
In a situation where the goods are directly drop ship from the Foreign Supplier to the other Malaysian buyers (e.g., Malaysian Buyer #2, #3 and #4), the e-Invoice treatments are as follows:
a) Malaysian Buyer #1 to issue a self-billed e-Invoice for the goods purchased from Foreign Supplier. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. Kindly refer to Step 3 of the illustration below for further clarity.
b) Malaysian Buyer #1 to issue e-Invoice to the other Malaysian Buyers #2, #3 and #4 for the goods sold respectively. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. Kindly refer to Step 6 of the illustration below for further clarity.

7. Where the goods are purchased from a Malaysian supplier, whom sources the goods from a foreign supplier and requests for the goods to be directly delivered directly to its customers, how should the e-Invoice and self-billed e-Invoice be issued?
In the above scenario where the goods are directly drop ship to Malaysian Buyer #2, the e-Invoice treatments are as follows:
a) Malaysian Buyer #1 to issue a self-billed e-Invoice for the goods purchased from the Foreign Supplier. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. As such, the Malaysian Buyer #1 may input the customs form reference number (e.g., Customs Form No. 8) at their discretion. Kindly refer to Step 5 of the illustration below for further clarity.
b) Malaysian Buyer #1 to issue an e-Invoice for the goods sold to Malaysian Buyer #2. The “Reference Number of Customs Form No. 1, 9, etc.” field is optional. Kindly refer to Step 8 of the illustration below for further clarity.

8. If I purchase goods from a foreign supplier but the foreign supplier requested for the goods to be directly delivered from their Malaysian supplier (located in a bonded warehouse / Free Zone) to me, am I required to input the customs form reference number?
In a scenario where the Malaysian Buyer purchases goods from a Foreign Supplier but the goods are directly delivered by the Foreign Supplier’s supplier in Malaysia (located in a bonded warehouse / Free Zone) to Malaysian Buyer, the e-Invoice treatments are as follows:
a) Malaysian Buyer to issue a self-billed e-Invoice for the goods purchased from the Foreign Supplier. The Malaysian Buyer is required to input the customs form reference number (e.g., Customs Form No. 9) under the “Reference Number of Customs Form No. 1, 9, etc.” field when issuing self-billed e-Invoice. Kindly refer to Step 10 of the illustration below for further clarity.
b) Malaysian Supplier to issue an e-Invoice for the goods sold to the Foreign Supplier. The “Reference Number of Customs Form No. 2” is an optional field. Kindly refer to Step 4 of the illustration below for further clarity.

9. In relation to exportation of goods to foreign buyers, when will the Malaysian supplier be required to issue an e-Invoice?
The Malaysian suppliers are required to issue an e-Invoice as per their current invoicing arrangement. If the customs form (e.g., Customs Form No. 2) is available, the Malaysian suppliers may include the customs form reference number (e.g., Customs Form No. 2) in the e-Invoice. Kindly note that this field is currently an optional field.
10. For low value goods that are declared under the electronic Pre-Alert Manifest (e-PAM) system, what should be input under “Reference Number of Customs Form No. 1, 9, etc.” field?
Further to harmonisation with RMCD, LHDNM provides a concession allowing taxpayers to not include the e-PAM reference number under the “Reference Number of Customs Form No. 1, 9, etc.” field and exclude such field when issuing self-billed e Invoice.
The following example is provided for ease of understanding.
Malaysian Buyers purchased goods from Foreign Supplier. A consolidator, who is responsible for the delivery of the goods to the Malaysian Buyers, will obtain RMCD’s clearance on the said goods purchased by the Malaysian Buyers in a single declaration.
In this regard, the Malaysian Buyers are required to issue self-billed e-Invoice to the to the Foreign Supplier upon receipt of Foreign Supplier’s invoice to record its purchase. The “Reference Number of Customs Form No.1, 9, etc.” field is optional when issuing self-billed e-Invoices. Kindly refer to the illustration below for further clarity.

11. For goods imported via loose container load (LCL) shipment, what should be input under “Reference Number of Customs Form No. 1, 9, etc.” field?
Further to harmonisation with RMCD, LHDNM provides a concession allowing taxpayers who import goods via LCL shipment to exclude the “Reference Number of Customs Form No. 1, 9, etc.” when issuing self-billed e-Invoice.
For arrangement similar to e-PAM, kindly refer to the illustration in the e-PAM FAQ above.
12. . For goods purchased under Delivered Duty Paid (DDP) incoterm, do I need to input customs form reference number in the “Reference Number of Customs Form No. 1, 9, etc.” field?
Further to harmonisation with RMCD, the current legislation requires the Malaysian Buyers to retain the relevant import documentation, even if the goods are purchased under DDP incoterm. As such, the Malaysian Buyer is required to obtain the relevant customs form reference number from the respective foreign supplier or third-party (e.g., agent, freight forwarder, etc.) for self-billed e-Invoice purposes.
13. Are MSMEs in Malaysia required to issue e-Invoice?
All persons conducting a business are required to implement e-Invoice in accordance with their respective implementation timeline as outlined under section 1.5 of the e-Invoice Guideline.
However, the Government of Malaysia has exempted taxpayers with annual turnover or revenue below RM150,000 to be exempted from the issuance of e-Invoice.
The following example is provided for ease of understanding:
Amzah operates a sole proprietorship, AMZ Enterprise. As at 31 December 2024, his business recorded total annual turnover or revenue of below RM150,000. Since his business is still below the threshold, Amzah is exempted from issuing e-Invoice (including issuance of selfbilled e-Invoice).
14. Does the exemption apply to all MSMEs?
The exemption applies to all categories of taxpayers (e.g., individuals, partnerships, companies, cooperatives, etc.) with an annual turnover or revenue below RM150,000. However, this exemption does not apply to the following taxpayers:
a) taxpayer with non-individual shareholder(s) (or equivalent) with annual turnover or revenue exceeding RM150,000; or
b) taxpayer is a subsidiary of a holding company with annual turnover or revenue exceeding RM150,000; or
c) taxpayer has related company / joint venture with annual turnover or revenue exceeding RM150,000.
The following example is provided for ease of understanding:
RC Cycling Sdn. Bhd. closes its financial year on 31 December every year. RC Cycling Sdn. Bhd. is a subsidiary of JT Motors Sdn. Bhd., which has implemented e-Invoice. The annual revenue recorded for RC Cycling Sdn. Bhd. as at 31 December 2024 is RM140,000. Even though the annual turnover or revenue is recorded below the RM150,000 threshold, RC Cycling Sdn. Bhd. does not qualify for the exemption for MSMEs because it is a subsidiary of another company (i.e., JT Motors Sdn. Bhd.) that is required to implement e-Invoice. As such, RC Cycling Sdn. Bhd. is required to implement e-Invoice starting from 1 July 2025.
15. When will MSMEs be required to implement e-Invoice if their annual turnover or revenue have reached or exceeded the threshold of RM150,000?
MSME is required to implement e-Invoice starting from 1 January in the second year following the year in which the total annual turnover or revenue exceeds RM150,000.
The following example is provided for ease of understanding:
Johan operates a business specialising in the sale of fertilisers, Winner Fertilizer Sdn. Bhd. and its accounting period ends every 31 December. As at 31 August 2024, his company already recorded an annual turnover or revenue exceeding RM150,000. Since the company has exceeded the exemption threshold, Winner Fertilizer Sdn. Bhd. is required to implement e-Invoice starting from 1 January 2026, which is from 1 January in the second year after the year in which the exemption threshold has been surpassed.
16. What are the determination for the implementation of e-Invoice for MSMEs?
The implementation of e-Invoices is applicable to taxpayers with an annual turnover or revenue exceeding RM150,000, determined as follows:
a) Taxpayers with audited financial statements: Based on annual turnover or revenue stated in the statement of comprehensive income in the audited financial statements for relevant year or
b) Taxpayers without audited financial statements: Based on annual revenue reported in the tax return for year of assessment relevant year or
c) Taxpayers with annual turnover or revenue exceeding RM150,000 for the relevant year. The following example is provided for ease of understanding: Kedai Berkat Gemilang recorded product sales income of RM155,000 as of 31 December
In view that the total income earned exceeds RM150,000, Kedai Berkat Gemilang is required to implement e-Invoice starting from 1 January 2027
17. For sole proprietorship, how will the mandatory implementation be determined if a sole proprietor has more than one business?
For sole proprietorship, the determination of annual turnover or revenue below RM150,000 threshold includes all sole proprietorship businesses owned or registered under the name of the respective sole proprietor.
The following example is provided for ease of understanding:
Awiyah owns several sole proprietorship businesses, namely RAM Cosmetic Enterprise, Princess Tailor and Fifty Cafe. The total annual turnover or revenue as of 31 December 2025 are as follows:

In view that the total annual turnover or revenue as of 31 December 2025 for all sole proprietorship businesses owned or registered under Awiyah’s name exceed RM150,000, Awiyah is required to implement e-Invoice starting from 1 January 2027.
18. Will MSMEs that have been mandated to implement e-Invoice be eligible for the exemption again if their annual turnover or revenue falls below the RM150,000 threshold in the subsequent years?
No exemption will be granted after the mandatory implementation year has been determined, and taxpayers are required to continue issuing e-Invoices even if their total annual turnover or revenue do not exceed RM150,000 in the subsequent years.
The following example is provided for ease of understanding: Similar facts pattern as Winner Fertilizer Sdn. Bhd. above. However, the annual turnover or revenue recorded as of 31 December 2025 has fallen below the RM150,000 threshold. Even
though the 2025’s annual turnover or revenue recorded is below the exemption threshold, Winner Fertilizer Sdn. Bhd. will remain obligated to implement e-Invoice. This is due to the requirement that no e-Invoice exemption will be provided once MSMEs have been mandated to implement e-Invoice.
19. For eligible taxpayers that are exempted from issuance of e-Invoice, are they required to issue consolidated e-Invoice and self-billed e-Invoice?
Eligible taxpayers who are exempted from the issuance of e-Invoice in accordance with section 1.6.1 of the e-Invoice Guideline are not required to issue consolidated e-Invoice and self-billed e-Invoice.
However, IRBM would encourage the exempted taxpayers to adopt e-Invoice on a voluntary basis.
20. If MSME has an annual turnover or revenue below RM150,000 and sells goods on a local e-commerce platform, is the MSME obligated to provide details to the e-commerce platform for issuance of e-Invoice?
Yes. This is because the obligation to issue e-Invoice / self-billed e-Invoice rests with the e-commerce platform provider, for all transactions conducted on the e-commerce platform.
21. If MSME conduct sales through physical store as well as e-commerce platform, must MSME issue e-Invoices for transactions from both sources?
MSME is required to issue e-Invoices for sales conducted through physical store.
As for the sales conducted through e-commerce platform, MSME is not required to issue any e-Invoice as the obligation to issue e-Invoice / self-billed e-Invoice rests with the e-commerce platform provider.
22. Following the release of Income Tax (Issuance of Electronic Invoice) Rules 2024 [P.U. (A) 265], is the 6-month interim relaxation period for taxpayers with annual turnover or revenue of more than RM100 million now starting on 1 October 2024, instead of the previously stated 1 August 2024?
No, the commencement of the 6-month interim relaxation period for taxpayers with an annual turnover or revenue of more than RM100 million remains unchanged, i.e., from 1 August 2024.
This interim relaxation period applies to all phases of e-Invoice implementation as stated in Section 16 of the e-Invoice Specific Guideline and in the immediate preceding question above