In what situations can I legally issue a self-billed e-Invoice? Can I do so just because the supplier did not issue an e-Invoice?

You cannot legally issue a self-billed e-Invoice simply because a supplier did not provide one. According to the official guidelines, self-billing is strictly prohibited unless the transaction falls within specific scenarios explicitly authorized by the Inland Revenue Board of Malaysia (IRBM).

If a supplier is not yet mandated to implement e-Invoices based on their revenue threshold, they may continue to issue standard receipts, which remain valid for tax substantiation during the transitional period. Large enterprises cannot compel suppliers (such as MSMEs) to issue e-Invoices before those suppliers' own mandatory implementation dates.

Authorized Situations for Self-Billed e-Invoices

A buyer acts as the issuer (assuming the role of the "Supplier") for the purpose of document creation and submission to the MyInvois System in the following designated situations:

• Transactions with Foreign Suppliers: When acquiring goods or services from a seller outside of Malaysia who does not use the Malaysian MyInvois System, the Malaysian buyer must self-bill to document the expense.

• Payments to Agents, Dealers, or Distributors: This includes monetary or non-monetary incentives (such as commissions) paid to intermediaries.

• e-Commerce Transactions: E-commerce platform providers are responsible for issuing self-billed e-Invoices to record the income earned by merchants or service providers (like delivery riders) for transactions made through the platform.

• Transactions with Individuals Not Conducting Business: If a business acquires a product or service from a private individual (e.g., purchasing a used car or renting property from a landlord who does not operate a rental business), the business buyer must issue a self-billed e-Invoice.

• Interest Payments: Buyers must self-bill for interest paid to private individuals, foreign lenders, or related companies that do not provide centralized treasury services.

• Profit and Dividend Distributions: Companies making distributions must self-bill to document the transaction unless they are listed on Bursa Malaysia or fall under specific exemptions.

• Insurance Claims and Benefits: Insurers must issue self-billed e-Invoices for claims, compensations, or benefit payouts (such as maturity benefits) made to policyholders or beneficiaries.

• Capital and Share Transactions: This includes payments related to capital reduction, share buybacks, or liquidation proceeds.

• Betting and Gaming: Licensed providers must issue self-billed e-Invoices for payouts to winners, excluding certain casino and gaming machine payouts until further notice.

Responsibilities of the Buyer in Self-Billing

1. Validation: The buyer submits the self-billed e-Invoice to IRBM for near real-time validation.

2. Sharing: Once validated, the buyer is obliged to share the document (or its visual representation with a QR code) with the actual supplier.

3. Classification: Buyers must use the correct machine-readable codes, such as Code 035 for the importation of services or Code 009 for e-commerce self-billing.

4. Correction: If a mistake is made, the buyer can cancel the self-billed e-Invoice within 72 hours; after this window, they must issue a self-billed credit, debit, or refund note to make adjustments.

What Self-Billed e-Invoice Is NOT Allowed For:

❌ Simply because the supplier:

     - Has not started e-Invoicing yet,

     - Has system issues such as MyInvois system downtime and not able to issue the e-Invoice to you temporarily,

     - Refuses or delays issuing the e-Invoice

❌ To “replace” a missing supplier invoice

❌ For general purchases that do not fall under permitted self-billed categories