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.


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.

Disclaimer: The information provided on this platform is for general informational purposes only. It does not constitute professional advice and should not be relied upon for making decisions. Wanconnect Consulting Group is not responsible for any errors or omissions in the content or for any actions taken based on the information provided. We recommend seeking professional advice for specific situations. Wanconnect Consulting Group reserves the right to modify, update, or remove any content without notice.

2 thoughts on “Where the Buyer does not require an e-Invoice

  1. i wish to clarify is a Sdn Bhd company that do not have e-invoice now, should buyer do self-billing for the particular expense under the company name?

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