Malaysia E-invoicing : Transactions with buyer scenarios

Malaysia E-invoicing: focus on buyer transactions and mandatory fields. Ensure compliance and streamline your invoicing process with our complete guide.

By
Ajith Kumar M
June 13, 2024
60 min

Introduction

The Inland Revenue Board of Malaysia (IRBM) issued the e-Invoice Guideline on 21 July 2023. This guideline addresses the scope of e-Invoice implementation, covering the concept and providing step-by-step guidance on the e-Invoice workflow. IRBM recognized the need to offer further guidance on specific areas of e-Invoice to help taxpayers gain a better understanding of certain e-Invoice treatments and ultimately implement e-Invoice successfully.

Objective

The specific guideline aims to provide further guidance on the issuance of e-Invoice related to the following areas:

  • Transactions with Buyers
  • Statements/Bills on a periodic basis
  • Disbursement and reimbursement
  • Employment perquisites and benefits
  • Certain expenses incurred by employees on behalf of the employer
  • Self-billed e-Invoice
  • Transactions involving payments (whether in monetary form or otherwise) to agents, dealers, or distributors
  • Cross-border transactions
  • Profit distribution (e.g., dividend distribution)
  • Foreign income
  • Currency exchange rate
  • E-commerce transactions

In this particular blog, we will focus exclusively on gaining a complete understanding of the topic "Transactions with Buyers."

Transactions with Buyers

Currently, businesses (Suppliers) issue a receipt, bill, or invoice in hardcopy and/or softcopy (e.g., via e-mail) to consumers (Buyers) to record a transaction, such as the sale of products or the provision of services to Buyers for personal consumption.

Upon the implementation of e-Invoice, Suppliers are required to issue e-Invoices for all their transactions. However, certain Buyers, particularly end consumers and specific businesses, may not require an e-Invoice as proof of expense.

To assist Suppliers in complying with e-Invoice requirements and to reduce the burden on both Suppliers and Buyers, the IRBM allows Suppliers to consolidate transactions with Buyers (who do not require an e-Invoice) into a consolidated e-Invoice on a monthly basis.

Where the Buyer Requires an e-Invoice

If a Buyer needs an e-Invoice for a transaction, they must inform the Supplier and provide the necessary details. The steps involved are:

  1. Confirmation: Supplier asks the Buyer if an e-Invoice is required.
  2. Information: Buyer provides the required information to the Supplier.
  3. Issuance: Supplier completes the necessary fields and issues the e-Invoice according to the guidelines.
  4. Validation: The validated e-Invoice can be used by the Buyer as proof of expense for tax purposes.

To ease the process, the IRBM provides concessions for individuals in providing their Tax Identification Number (TIN) and identification details:

  • Malaysian Individuals:
    • TIN
    • MyKad/MyTentera number
    • Both TIN and MyKad/MyTentera number
  • Non-Malaysian Individuals:
    • TIN
    • Both TIN and passport number/MyPR/MyKAS number

If a non-Malaysian individual does not have a TIN, the Supplier may use a general TIN along with the individual's passport number/MyPR/MyKAS number.

Transactions with Buyers – Issuance of e-Invoice to Buyers

In summary, individual Buyers need to provide specific details for the issuance of an e-Invoice.

Individual Buyer's details to be provided to Supplier

No Data field Details to be included by Supplier in e-Invoice Additional Remarks
1 Buyer’s Name Name of individual Buyer For Malaysian individuals: Full name as per MyKad/ MyTentera
For non-Malaysian individuals: Full name as per passport/ MyPR/ MyKAS
2 Buyer’s TIN TIN of individual Buyer For Malaysian individuals
  1. Option 1: TIN only
  2. Option 2: MyKad/ MyTentera identification number only
  3. Option 3: Both TIN and MyKad/ MyTentera identification number
For non-Malaysian individuals
  1. Option 1: TIN only
  2. Option 2: Both TIN and passport number/ MyPR/ MyKAS identification number
3 Buyer’s Registration/ Identification Number/ Passport Number Details of registration/ identification number/ passport number For clarity, (i) refers to the TIN assigned by IRBM. In the event that the non-Malaysian individual does not have a TIN, Supplier may use the general TIN along with the passport/ MyPR/ MyKAS identification number of the said individual.
4 Buyer’s Address Address of individual Buyer Individual Buyer is required to provide residential address
5 Buyer’s Contact Number Telephone number of individual Buyer Individual Buyer is required to provide a contact number
6 Buyer’s SST Registration Number SST registration number of individual Buyer Where applicable, individual Buyer to provide SST registration number
If individual Buyer is not registered for SST, Supplier to input “NA”

Table – Individual Buyer’s details to be provided to Supplier

The individual Shipping Recipient must provide the following details for the issuance of the e-Invoice:

Individual Shipping Recipient’s details to be provided to Supplier

No Data field Details to be included by Supplier in Annexure to the e-Invoice Additional Remarks
1 Shipping Recipient’s Name Name of individual Shipping Recipient For Malaysian individuals: Full name as per MyKad / MyTentera
For non-Malaysian individuals: Full name as per passport / MyPR / MyKAS
2 Shipping Recipient’s Address Address of individual Shipping Recipient Individual Shipping Recipient is required to provide residential address
3 Shipping Recipient’s TIN TIN of individual Shipping Recipient For Malaysian individuals
  1. Option 1: TIN only
  2. Option 2: MyKad / MyTentera identification number only
  3. Option 3: Both TIN and MyKad / MyTentera identification number
For non-Malaysian individuals
  1. Option 1: TIN only
  2. Option 2: Both TIN and passport number / MyPR / MyKAS identification number
4 Shipping Recipient’s Registration / Identification Number / Passport Number Details of registration / identification number / passport number For non-Malaysian individuals
  1. Option 1: TIN only
  2. Option 2: Both TIN and passport number / MyPR / MyKAS identification number
For clarity, (i) refers to the TIN assigned by IRBM. In the event that the non-Malaysian individual does not have a TIN, Supplier may use the general TIN along with the passport / MyPR / MyKAS identification number of the said individual.

If the individual Buyer and/or individual Shipping Recipient (where applicable) provides either a Tax Identification Number (TIN) or a MyKad/MyTentera identification number (instead of both), the Supplier should include the following details for e-Invoice purposes:

  1. Tax Identification Number (TIN): If provided, this number should be recorded as the primary identifier for the individual.
  2. MyKad/MyTentera Identification Number: If provided, this number should be recorded as the primary identifier for the individual.

This ensures that the e-Invoice contains sufficient identification information to comply with regulatory requirements, even if only one of the identifiers is provided.

No Option Data field Details to be included by Supplier in e-Invoice
1 Option 1 (for Malaysian and non-Malaysian individuals), where the individual Buyer / individual Shipping Recipient only provides TIN Buyer’s / Shipping Recipient’s TIN Supplier to input the TIN as provided by individual Buyer / individual Shipping Recipient
Buyer’s / Shipping Recipient's Registration / Identification Number / Passport Number Supplier to input “000000000000” in the e-Invoice
2 Option 2 (for Malaysian individuals), where the individual Buyer / individual Shipping Recipient only provides MyKad / MyTentera identification number Buyer’s / Shipping Recipient's TIN Supplier to input “EI0000000010” in the e-Invoice
Buyer’s / Shipping Recipient's Registration / Identification Number / Passport Number Supplier to input MyKad / MyTentera identification number provided by the individual Buyer / individual Shipping Recipient

Details of TIN and identification number/ passport number to be included bySupplier for issuance of e-Invoice to individual Buyer / individual Shipping Recipient

Example 1:

Mr. Ahmad (Buyer) spent RM2,500 to buy a smartphone from Greta Solutions (Supplier) and has requested an e-Invoice to be issued.

Tech Solutions Sdn Bhd has requested Mr. Ahmad’s personal details to proceed with the issuance of the e-Invoice. Mr. Ahmad provided all the necessary details, including his MyKad identification number, except for his Tax Identification Number (TIN). Despite not having the TIN, Tech Solutions Sdn Bhd can still issue an e-Invoice to Mr. Ahmad.

Upon receiving the validated e-Invoice, Mr. Ahmad can use it as proof of expense for tax purposes.

The following image illustrates an example of a validated e-Invoice in PDF format issued by Tech Solutions Sdn Bhd to Mr. Ahmad.

Where the Buyer Does Not Require an e-Invoice

  1. If the Buyer does not require an e-Invoice, the Supplier will issue a regular receipt to the Buyer, as per the current business practice. This receipt does not need to be submitted for IRBM’s validation since it is not an e-Invoice.
  2. The Supplier can 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.
  3. For consolidated e-Invoices, IRBM allows Suppliers to use one or a combination of the following methods:
    • Presenting the summary of each receipt as separate line items in the consolidated e-Invoice.
    • Listing the receipts (in a continuous receipt number sequence) as line items. If there is a break in the receipt number chain, the next sequence will be included as a new line item.
    • Branches or locations can submit consolidated e-Invoices using either of the above methods for receipts issued by those branches or locations.
  4. To enhance the performance of the MyInvois System, the following limitations are set:
    • A maximum size of 5MB per submission.
    • A maximum of 100 e-Invoices per submission.
    • A maximum size of 300KB per e-Invoice.Suppliers can split receipts into several consolidated e-Invoices to adhere to these requirements.
  5. Note that consolidation does not apply to self-billed e-Invoices, except in the following cases:
    • Acquisition of goods or services from individual taxpayers who are not conducting a business.
    • Interest payment to the public, regardless of whether they are businesses or individuals.

Example 2:

Hibiscus Mart Sdn Bhd (Hibiscus Mart) is a small retail business with branches in Penang and Kuala Lumpur. In October, Hibiscus Mart issued normal receipts and made the following sales without issuing

an e-Invoice:

  • Penang branch: 500 transactions amounting to RM25,000
  • Kuala Lumpur branch: 2,000 transactions amounting to RM65,000

Within seven calendar days after the end of October (i.e., by 7 November), Hibiscus Mart issues two separate consolidated e-Invoices. One e-Invoice is for the Penang branch and another for the Kuala Lumpur branch, each reflecting the total sales for the respective branch. Hibiscus Mart consolidates the sales by presenting each receipt number chain as separate line items. Additionally, all receipt reference numbers that contribute to the total sales are included in the “Description” field for the relevant branch.

Example of validated consolidated e-Invoice in PDF format(Kuala Lumpur branch)

Meanwhile, Cer-Mart Sdn Bhd, a competitor of Hibiscus Mart, has four branches located in the same area as Hibiscus Mart, as well as in Malacca and Ipoh. Cer-Mart issued a consolidated e-Invoice to record its sales for the month of October. The sales made by each branch in October (with no individual e-Invoices issued) are as follows:

  • Penang branch: 2,500 transactions amounting to RM75,000
  • Kuala Lumpur branch: 5,800 transactions amounting to RM125,000
  • Malacca branch: 1,300 transactions amounting to RM22,000
  • Ipoh branch: 1,850 transactions amounting to RM25,300

Unlike Hibiscus Mart, Cer-Mart Sdn Bhd decided to consolidate its sales revenue for each branch into separate consolidated e-Invoices, presenting each receipt as a single line item. Cer-Mart is required to include all receipt reference numbers that make up the total sales in the "Description" field.

If Buyers require an e-Invoice after receiving a receipt from the Supplier, they can request an e-Invoice within the month of the transaction. This timeframe allows the Supplier to include the receipt in the consolidated e-Invoice. Buyers are encouraged to request an e-Invoice as soon as possible after receiving the receipt to ensure timely processing. Suppliers should create and submit e-Invoices to IRBM for validation promptly to fulfill Buyers' requests.

Summary of Steps for Issuing a Consolidated e-Invoice When a Buyer Does Not Require One:

  1. Supplier confirms with Buyers if an e-Invoice is required.
  2. If Buyers confirm that no e-Invoice is needed, the Supplier issues a receipt as usual.
  3. Within seven calendar days after the end of the month, the Supplier retrieves all receipt details from the previous month and issues a consolidated e-Invoice as proof of income.
  4. The Supplier issues the consolidated e-Invoice accordingly.

The process of issuing a consolidated e-Invoice follows the same workflow as discussed in the e-Invoice Guideline, with these exceptions:

  • Once the consolidated e-Invoice is validated, IRBM will notify only the Supplier (not the Buyer), as this e-Invoice is issued to the general public. Therefore, there will be no request for rejection from the Buyer.
  • The validated e-Invoice serves as the Supplier's proof of income and does not need to be shared with the Buyer.

For the consolidated e-Invoice, the Supplier must complete the required fields, including the Buyer's details and certain transaction details using the appropriate information.

No Data field Details to be included by Supplier in e-Invoice Additional Remarks
1 Buyer’s Name Name of Buyer Supplier to input “General Public” in the e-Invoice
2 Buyer’s TIN TIN of Buyer Supplier to input “EI0000000010” in the e-Invoice
3 Buyer’s Registration/ Identification Number/ Passport Number Details of registration/ identification number/ passport number Supplier to input “NA”
4 Buyer’s Address Address of Buyer Supplier to input “NA”
5 Buyer’s Contact Number Telephone number of Buyer Supplier to input “NA”
6 Buyer’s SST Registration Number SST registration number of Buyer Supplier to input “NA”
7 Description of Product/ Services Details of products or services being billed for a transaction with Buyer IRBM allows the Suppliers to adopt one (or a combination) of the following methods:
(a) Summary of each receipt is presented as separate line items
(b) List of receipts (in a continuous receipt number) is presented as line items (i.e., where there is a break of the receipt number chain, the next chain shall be included as a new line item)
(c) Branch(es) or location(s) will submit consolidated e-Invoice, adopting either (a) or (b) above for the receipts issued by the said branch(es) or location(s)
Note that for any method adopted by businesses, the receipt reference number for each transaction is required to be included under this field in the consolidated e-Invoice

Table - Details to be included by Supplier for issuance of consolidated e-Invoice

Example 3

Siti, Mei Ling, and Amir (Buyers) dined at Restaurant XYZ (Supplier) on 8 July, 17 July, and 21 July respectively. Since they did not request an e-Invoice, Restaurant XYZ issued standard receipts to them instead.

On 1 August 2025 (i.e., within seven calendar days after the month-end), Restaurant XYZ aggregates all receipts for the month of July and issues a consolidated e-Invoice, which is then transmitted to IRBM for validation.

Restaurant XYZ is not required to share the validated consolidated e-Invoice with its Buyers, as the consolidated e-Invoice is issued to the general public rather than specific Buyers. This serves as proof of income for Restaurant XYZ, and since its Buyers did not request any e-Invoice, they do not need to receive the consolidated e-Invoice. Below is an example of the consolidated e-Invoice in XML or JSON format issued by Restaurant XYZ via API.

Please note that the formats shown below are for illustration purposes only, and the actual formats are provided in the Software Development Kit (SDK).

Below is an example of the consolidated e-Invoice issued by Restaurant XYZ (in PDF format) after aggregating all issued receipts, which have been submitted to and validated by IRBM:

Example of validated consolidated e-Invoice in PDF format

The above example is for illustration purposes only and is subject to change.

Example 4

Same facts as in Example 3. On 28 July 2025, Amir (Buyer) decided to request an e-Invoice for his meal (receipt number: 12442) on 21 July 2025.

Amir contacted Restaurant XYZ (Supplier) to inquire about converting his receipt to an e-Invoice. Since Restaurant XYZ provides a web portal/mobile application for this purpose, Amir visited the portal/application and provided his personal details to obtain the e-Invoice.

The request for the issuance of an e-Invoice should be made by Amir no later than 31 July 2025 (i.e., within the month of the transaction).

Example 5

Aisyah (Buyer) purchased badminton rackets and shuttlecocks from Sukan Sdn Bhd (Supplier) on 30 September 2025. She did not request an e-Invoice at check-out as she was running late for her class.

Swamped with errands and coursework, Aisyah forgot to request an e-Invoice from Sukan Sdn Bhd’s web portal on the same day of her purchase. She only requested an e-Invoice on 1 October 2025.

Since Aisyah did not request an e-Invoice within the month of the transaction (i.e., by 30 September 2025), Sukan Sdn Bhd may deny her request for the issuance of an e-Invoice based on the abovementioned guidance.

As Sukan Sdn Bhd had already issued the consolidated e-Invoice for receipts issued in September 2025, they rejected Aisyah’s request accordingly.

Certain Activities Requiring Individual e-Invoices for Each Transaction (i.e., consolidation of e-Invoice is not allowed)

For specific activities, taxpayers must issue an e-Invoice for each transaction with Buyers. Consolidated e-Invoices are not permitted for these activities. Taxpayers will need to collect the Buyer’s details for each e-Invoice issuance.

Currently, the industries and transactions where an e-Invoice is required for each transaction include the following:

No Industry/Activity Types of activities/transactions where consolidated e-Invoice is not allowed
1 Automotive Sale of any motor vehicle
Note that motor vehicle refers to a vehicle of any description, propelled by means of mechanism contained within itself and constructed or adapted to be capable of being used on roads, and includes a trailer
2 Aviation
  • Sale of flight ticket
  • Private charter
3 Luxury goods and jewellery Details will be released in due course
Note that this is currently being put on hold until such time when the details are made available. Taxpayers are allowed to issue consolidated e-Invoice (in the event the buyers do not request for e-Invoice) until further notice
4 Construction Construction contractor undertaking construction contract, as defined in the Income Tax (Construction Contracts) Regulations 2007
5 Wholesalers and retailers of construction materials Sale of construction materials, regardless of volume sold
Note that construction material is defined as any type, size and nature of material, initial, temporary, intermediate or finished whether manufactured locally or imported used for the purposes of construction industry as specified under the Fourth Schedule of Lembaga Pembangunan Industri Pembinaan Malaysia Act 1994
6 Licensed betting and gaming Pay-out to winners for all betting and gaming activities
Note that however pay-out to winners in relation to betting and gaming (i) in casino and (ii) from gaming machines are exempted from e-Invoice until further notice
7 Payment to agents/dealers/distributors Payments made to agents, dealers or distributors
Pursuant to Section 83A(4) of the Income Tax Act 1967, “agent, dealer or distributor” refers to any person who is authorised by a company to act as its agent, dealer or distributor, and who receives payment (whether in monetary form or otherwise) from the company arising from sales, transactions or schemes carried out by him as an agent, dealer or distributor

Table – Activities that require e-Invoice to be issued for each transaction and consolidated e-Invoice would not be allowed

IRBM recognizes the potential challenges in issuing e-Invoices to individual Buyers for the types of activities and transactions listed.

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In this blog, we've covered the essential aspects of Malaysia's e-Invoicing system, from understanding mandatory fields to handling transactions with Buyers and issuing consolidated e-Invoices. We hope this information has been helpful in guiding you through the e-Invoicing process.

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