Where the Buyer does not require an e-Invoice

The IRBM has exempted certain categories of taxpayers from the e-Invoicing process . These include:

1. Any Insurance Company
2. Banking Company including a Financial Institution, including a Non-Banking Financial Company (NBFC)
3. Goods Transport Agency (GTA) transporting goods by road in a goods carriage services
4. A registered person who supplies passenger transportation services
5. A registered person who supplies services by way of admission to the exhibition of cinematographic films in multiplex services
6. A Special Economic Zone unit
7. A department of government and local authority

In addition, the IRBM has clarified that an e-Invoice is not required for the following :

1. Employment income
2. Pension
3. Alimony
4. Distribution of dividend in specific circumstances (Refer to Section 11 of e-Invoice Specific Guideline for more details)
5. Zakat
6. Scholarship

According to the IRBM e-Invoice Specific Guideline Version 1.1 , where the buyer does not require an e-Invoice, the supplier will issue a normal receipt/bill/invoice to the buyer, which is the same as the current business practice.

However, such receipt/bill/invoice would not be required to be submitted for IRBM’s validation as these documents are not e-Invoices. The supplier will be allowed to aggregate transactions with buyers who do not require an e-Invoice on a monthly basis and submit a consolidated e-Invoice to IRBM, within seven (7) calendar days after the month end. Suppliers may consider the following consolidation methods:

• The summary of each receipt/bill/invoice is presented as separate line items in the consolidated e-Invoice is as follow:

• The summary of all the receipts/bills/invoices is presented as a single line item in the consolidated e-Invoice.

The invoice below provides an example of an e-Invoice where the summary of all the receipts/bill/invoice is presented as a single line item in the consolidated e-Invoice.

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Summary: Issuance of Consolidated e-Invoice When Buyer Does Not Require Individual e-Invoices

When a buyer does not require an individual e-invoice, suppliers can follow these steps to issue a consolidated e-invoice:

1. Confirmation from Buyer:

• The supplier seeks confirmation from the buyer regarding the need for an e-invoice.
• If the buyer confirms that no e-invoice is necessary, the supplier proceeds with issuing the regular statement or bill (following the existing business practice).

2. Consolidation Process:

• Within seven (7) calendar days after the billing period (as per the supplier’s practice), the supplier retrieves all previously issued statements/bills.
• The supplier then generates a consolidated e-invoice, serving as proof of their income and expenses.

3. Consolidated e-Invoice Details:

• The consolidated e-invoice must adhere to the required fields.
• The process for issuing the consolidated e-invoice follows a similar workflow to the standard e-invoice process.
• Notably, once the consolidated e-invoice is validated, the tax authority (IRBM) notifies the supplier only (no notification is sent to the buyer, as this is a general public e-invoice). Consequently, there is no opportunity for buyer rejection.

The validated e-invoice serves as the supplier’s official proof of income and expenses and need not be shared with the buyer.

Certain activities that require e-Invoice to be issued for each transaction.

The following are the activities or transactions of industries where an e-Invoice is required to be issued for each transaction:

• It is important to note that the above list is not exhaustive, and the IRBM may add or remove activities or transactions from the list from time to time.

Our services include:

• Offer advice on selecting the right e-invoicing system based on the specific needs and requirements of clients.
• Help organizations optimize their invoicing processes by identifying inefficiencies, automating manual tasks, and streamlining workflows.
• Offer recommendations for improving the end-to-end invoicing lifecycle.
• Advise on integration strategies for e-invoicing systems with existing ERP, accounting, and other business systems.
• Provide guidance on implementing robust security measures and ensuring compliance with data protection regulations when transmitting and storing e-invoice data.
• Assist organizations in managing the transition to e-invoicing by developing change management strategies, conducting training sessions, and facilitating communication with stakeholders.
• Identify potential risks and challenges associated with e-invoicing implementation, such as system downtime, data breaches, or non-compliance issues.
• Offer recommendations for mitigating risks and ensuring business continuity.