e-Invoicing Implementation: A final check to the meet the first deadline of 7th September 2024
It’s a wrap for the first month of e-Invoicing implementation.

Should there be any shortcomings in the implementation, there are avenues to make good any such shortcomings without penalty by 7^th September 2024, a date which may be dubbed as the first ‘final deadline’ for e-Invoice compliance for companies with turnover in excess of RM100 million. Failure to meet the minimum requirements via either API or manually at MyInvois portal by the end of this week (i.e. 7th September) would lead to penalty amid the flexibilities for the initial 6-month period.

Here is a short checklist of matters to comply by 7^th September 2024:

1. Have you raised transactional e-Invoice for all ‘sale transactions’ during the month? This includes revenue items as well as other transactions such as sale of fixed assets, realization of investment in shares, sale of scrap and interest income from overseas. Should there be a compliance gap, you may compile the value of such transactions and lodge a consolidated e-Invoice by 7^thSeptember 2024 for the total amount. This consolidated e-Invoice is a simple act of registering total sale value during the month without having to compile or validate particulars such as customer name, address, SSM number and TIN number.
2. Has other documentation such as credit note, debit note, and refund note issued during August 2024 been validated for e-invoicing purposes? Otherwise, do the necessary corrective action at the soonest.
3. Did you observe the requirement to issue self-billed e-Invoice on domestic transactions during August 2024? The scope of this requirement includes:
4. Payments to individuals (e.g. rental to landlord or fee to an individual (other than employment income))
5. Payments to agents, dealers and distributors (commonly known as ADDs) – regardless of whether the ADD is an individual or a company

• Payment of inter-company interest (or accrual of inter-company interest expense)

If there are shortcomings in compliance, you may perform consolidated self-billed e-Invoice by 7^th September 2024 based on the total value of such missed transactions (i.e. limited reporting).

As for payments to foreign vendors for goods or services, if the system is not ready to comply with self-billed e-Invoice on transaction-by-transaction basis by 30^th September 2024, a consolidated approach may be adopted for the self-billed e-Invoice with limited particulars by 7^th October 2024 – yes, there is over one month to go for this ‘final deadline’ in respect of importation of goods and services made during the month August 2024.

The pointers above incorporate the flexibilities given during the initial 6-month period and hence may require adaptation for any taxpayer who have decided to perform full implementation by 1^st August 2024 to obtain accelerated capital allowance on ICT equipment and software costs.

Of course, companies with annual turnover not exceeding RM100 million have until 1^st January 2025 or 1^st July 2025 (based on size of respective company) to prepare for e-Invoicing implementation.

We wish all taxpayers success in e-Invoicing implementation by the stipulated due dates.

Disclaimer: This e-Alert include our opinion and views based on our interpretation based on information available at the time of writing. The information herein is not meant to be exhaustive. Strictly no liability assumed. Kindly seek case-specific consultation prior to any action.