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self billing e invoices

E-INVOICE

Understanding the Essentials of Self-Billed e-Invoices

When a sale or transaction is completed, the typical process involves the supplier issuing an e-invoice to acknowledge their income and provide the buyer with a record of their expenditure. 

This e-invoice serves as both proof of income for the supplier and a detailed expense record for the buyer. However, in specific circumstances, an alternative approach is permitted: a self-billed e-invoice

In such cases, a party other than the supplier can generate this invoice on the supplier’s behalf, a process known as self-billing. This method ensures that transactions are documented accurately and compliantly.  

In this article, we explore the fundamentals of self-billed e-invoices, applications, and how they integrate into the broader e-invoice system.

What is a Self-Billed e-Invoice?

In typical business e-invoice transactions, the supplier generates an invoice once a sale is finalized.

This invoice fulfills two primary functions: it confirms the supplier’s income and gives the buyer a record for tracking expenses. However, an exception applies when dealing with individual, unregistered sellers. 

In these cases, the buyer is allowed to create a self-billed e-invoice on behalf of the supplier to document the transaction. This self-billed e-invoice must then be validated by the Inland Revenue Board (LHDN) before it can be used as a valid expense record for the buyer’s tax purposes. 

When is Self-Billed e-Invoicing Allowed?

Self-billed e-invoices are permitted in several key scenarios:

1. Payments to Intermediaries

When dealing with agents, dealers, or distributors, buyers can issue a self-billed e-invoice to streamline the transaction and record expenses accurately.

2. International Transactions

For goods or services provided by foreign suppliers, self-billed e-invoicing allows buyers to handle invoicing, facilitating smoother international trade.

3. Profit Distribution

In cases of profit distribution, such as dividends, self-billed e-invoices simplify the documentation process.

4. e-Commerce Transactions

Online sales platforms and intermediaries can use self-billed e-invoices to enhance efficiency in processing transactions.

5. Betting and Gaming Winnings

Self-billed e-invoicing ensures accurate record-keeping for payouts to winners in betting and gaming activities.

6. Individual Taxpayers

When acquiring goods or services from individual taxpayers who are not conducting a business, self-billed e-invoicing simplifies the transaction and ensures proper record-keeping.

    The Role of e-Invoice Systems and Invoice Software in Self-Billing

    Implementing an effective e-invoice system is important for managing self-billed e-invoices efficiently. 

    The system should support the creation, validation, and submission of e-invoices to ensure compliance with regulations. Invoice software in Malaysia plays a significant role in this process, offering features that streamline invoicing tasks and integrate with accounting systems.

    1. Integration

    Modern invoice software integrates seamlessly with other financial systems, ensuring that self-billed e-invoices are recorded accurately and efficiently.

    2. Validation

    Invoice software often includes validation features that ensure self-billed e-invoices meet regulatory requirements before submission to tax authorities.

    3. Automation

    Automated invoicing processes reduce manual effort and errors, enhancing the overall efficiency of financial operations.

    4. Compliance

    Invoice software designed for the Malaysian market incorporates local tax regulations, ensuring that self-billed e-invoices comply with national standards.

      How to Issue a Self-Billed e-Invoice

      Issuing a self-billed e-invoice involves several steps:

      Step 1: Determine Eligibility

      Ensure that the transaction qualifies for self-billing based on the scenarios outlined earlier.

      Step 2: Gather Information

      Collect necessary details about the transaction, including the supplier’s information, transaction amount, and any applicable tax rates.

      Step 3: Create the Invoice

      Use an e-invoice system or invoice software to generate the self-billed e-invoice. Ensure that all required details are accurately entered.

      Step 4: Submit for Validation

      Submit the self-billed e-invoice to the Inland Revenue Board of Malaysia (IRBM) for validation. The invoice must be validated before it can be used for tax purposes.

      Step 5: Record Keeping

      Maintain records of the self-billed e-invoice and any related documentation for future reference and compliance checks.

      Examples of Self-Billed e-Invoice Usage

      To illustrate the practical application of self-billed e-invoices, consider the following examples:

      Scenario A

      Payments to Agents

      Suppose a company, XYZ Bhd, pays a commission to a sales agent, Danny Wong. XYZ Bhd generates a self-billed e-invoice reflecting the commission amount and submits it for validation. Danny Wong uses this invoice for tax reporting purposes.

      Scenario B

      International Trade

      A Malaysian business, ABC Sdn Bhd, imports goods from a foreign supplier. To simplify invoicing, ABC Sdn Bhd issues a self-billed e-invoice for the imported goods and submits it to IRBM. This process facilitates smoother record-keeping and compliance with tax regulations.

      Scenario C

      e-Commerce Transactions

      An online marketplace, BeliSekarang, uses self-billed e-invoices for transactions involving multiple merchants. This approach streamlines invoicing and ensures accurate expense tracking for both the platform and its users. 

      Final Takeaways  

      Self-billed e-invoices offer numerous advantages for both businesses and individuals. They streamline financial operations by allowing buyers to issue invoices, thus reducing administrative burdens. 

      This method also enhances accuracy, as the invoices reflect the actual transaction details recorded by the buyer, which minimizes the risk of errors. Additionally, self-billed e-invoices support compliance with tax regulations, as validated invoices are accepted for tax purposes. 

      They simplify record-keeping by providing a clear and organized record of transactions, making financial management and tax reporting more efficient. For international transactions, self-billed e-invoices facilitate smoother invoicing processes, easing the complexities of cross-border trade. 

      Upon familiarizing yourself with the eligibility requirements and benefits of self-billing e-invoices, you can enhance your financial processes and simplify record-keeping.   

      FAQ

      Questions Regarding E-Invoicing

      Which E-Invoicing frameword will be used in Malaysia?

      The Peppol E-Invoicing framework is considered to be the most suitable for implementation in Malaysia due to its maturity, interoperability, and well-governed standards. It is also the most widely used E-Invoicing framework globally, adopted by more than 20 countries. (refer to country list HERE)

      What is a Peppol Authority?

      The function of a Peppol Authority is to manage the implementation of the Peppol framework in a particular country. This includes localising the Peppol standards to suit local requirements and to accrediting service providers that adhere to the Peppol standards. MDEC functions as the Peppol Authority for Malaysia.

      Is it compulsory for every business to implement E-Invoicing for tax reporting?

      According to LHDNM’s website, businesses with an annual turnover of RM100 million and above will be mandated to implement e-Invoice for tax compliance on 1st August 2024. The implementation of e-Invoice will be mandatory for all businesses on 1st July 2025. For the latest information on e-Invoicing for tax reporting and compliance, please click here.

      We are a large company/business owner. Should I replace my current accounting software/ERP System to adopt this initiative?

      You should not be required to replace your current systems. This initiative aims to standardise the specification and message format used for the transmission/exchange of e-invoices between different accounting software/ERP systems. The standardisation of the e-Invoice format is technically configured in your accounting software by your service provider. Consult your accounting service provider to determine whether they can/will support the Peppol framework. If you would like to know more details, you may reach out to us at clic@mdec.com.my

      Is e-Invoice applicable to transactions in Malaysia only?

      No, e-Invoice is applicable to both domestic and cross-border transactions. The cross-border transactions include import and export activities.

      For clarity, the compliance obligation is from the issuance of e-Invoice perspective. In other words, taxpayers who are within the annual turnover or revenue threshold as specified in Section 1.5 of the e-Invoice Guideline are required to issue and submit e-Invoice for IRBM’s validation according to the implementation timeline.

      What are the thresholds for e-Invoice implementation to be applicable to taxpayers?

      All taxpayers are required to implement e-Invoice according to the annual turnover or revenue thresholds.

      In relation to a company, the annual turnover or revenue threshold refers to the annual turnover or revenue value as stated in the statement of comprehensive income in the FY22 Audited Financial Statements.

      Are all industries included in the e-Invoice implementation? Are there any industries exempted?

      Currently, there are no industries that are exempted from the e-Invoice implementation.

      Note that certain persons and types of income and expense are exempted from e-Invoice implementation. Refer to Section 1.6 of the e-Invoice Guideline for further details.

      Will all businesses be required to issue e-Invoice?

      Yes, all businesses will be required to issue e-Invoice in accordance to the phased mandatory implementation timeline, which is based on the business’ annual turnover or revenue threshold.

      Is there any adjustment window allowed to the supplier to cancel an invoice submitted to IRBM?

      Yes, there is a 72-hour timeframe for the e-Invoice to be cancelled by the supplier. Refer to section 2.4.6 of the e-Invoice Guideline for further details.

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