Do you need a self-billed e-Invoice?
A self-billed e-Invoice is one the buyer issues on the supplier's behalf. Where a Malaysian business is inside LHDN's e-Invoice mandate, LHDN requires it to raise one when buying from a supplier outside Malaysia, because a foreign seller is not mandated to implement Malaysia's e-Invoice. As at 23 September 2026, businesses with annual turnover or revenue below RM3 million are generally exempt from issuing e-Invoices, including self-billed ones. That exemption is removed for companies owned by, or connected to, a business at RM3 million or more.
- Under RM3 million turnover: LHDN exempts you from issuing e-Invoices, and states the exemption includes self-billed e-Invoices. The test turns on the relevant year's turnover, not today's.
- The threshold moved three times in fifteen months - RM500,000, then RM1 million, then RM3 million on 1 September 2026. Most published guidance still quotes the older figures.
- A small company can still be caught if it has a corporate shareholder, holding company, related company or joint venture at RM3 million or more.
- For taxpayers inside the mandate, LHDN sets the deadline for a software subscription bought from a foreign supplier at the end of the month after payment or receipt of the invoice, whichever came first.
Reviewed 23 September 2026 against e-Invoice Guideline v4.8 and e-Invoice Specific Guideline v4.9. LHDN revises these roughly monthly and overwrites the PDFs in place - the file named IRBM-e-Invoice-Guideline.pdf silently became version 4.8 on 30 August 2026 - so if today is well past this date, check hasil.gov.my before relying on anything here.
Every statement of LHDN's rules below is sourced to a named document with its version and date. One section, Is there a way to avoid it entirely?, is our own reading rather than a quotation, and is marked as such where it appears.
This is a summary of published guidance, not tax advice. Office Niaga is a Google Workspace reseller, not a tax agent. For your own position, speak to a licensed tax agent.
What is a self-billed e-Invoice?
Normally the seller issues the invoice. In certain situations LHDN reverses that, and the buyer issues an e-Invoice on the seller's behalf - a self-billed e-Invoice. The buyer submits it to MyInvois for validation in the seller's place.
The e-Invoice Specific Guideline (version 4.9, 7 September 2026) lists nine circumstances at section 8.3. Software bought from abroad falls under the second.
| When a buyer must self-bill | Typical example |
|---|---|
| Payments to agents, dealers or distributors | Commission to a sales agent |
| Goods sold or services rendered by foreign suppliers | Software billed by an entity outside Malaysia - check the supplier name on the invoice, because several vendors bill some Malaysian customers through a local entity |
| Profit distribution | Dividends |
| e-commerce transactions | Sales through a platform |
| Pay-outs to betting and gaming winners | Casino and gaming machine pay-outs are exempted until further notice |
| Transactions with individuals not conducting a business, where no other circumstance applies | Buying equipment from a private seller |
| Interest payments | Five carve-outs apply, including interest paid by an employee to an employer |
| Insurance claim, compensation or benefit payments | An insurer paying a claim |
| Capital reduction, share buyback, redemption or liquidation proceeds | Returning capital to shareholders |
The Specific Guideline lists nine.
Is Google a foreign supplier?
Where the invoice comes from Google's Singapore entity, LHDN's definition appears to cover it. LHDN's definition at section 10.2 is wide: a foreign supplier is "any supplier operating outside of Malaysia / not established in Malaysia, including non-Malaysian individual". Google Workspace bought direct is supplied by Google Asia Pacific Pte. Ltd., a Singapore company.
Section 10.4.3 is explicit about what follows: "Given that the Foreign Seller is not mandated to implement Malaysia's e-Invoice, the Malaysian Purchaser is required to issue a self-billed e-Invoice to document the said expense."
LHDN's General FAQs confirm the same applies to purchases through a foreign platform, not only direct ones.
What if my turnover is under RM3 million?
Then, as things stand, you have no obligation to issue e-Invoices - including no obligation to issue self-billed ones. The e-Invoice Guideline (version 4.8, 30 August 2026) exempts at section 1.6.1(e) "Taxpayers with an annual turnover or revenue of less than RM3,000,000", and the wording covers "issuance of e-Invoice (including issuance of self-billed e-Invoice)".
Two qualifications matter before you rely on that. The exemption is conditional on your ownership structure - see the next section. And the test turns on the relevant year's turnover, not this month's: LHDN's FAQs state that a business under the threshold in YA2022 which later reached RM3 million in YA2023 to YA2025 implements from 1 July 2026.
Exempt means exempt from issuing e-Invoices. That is all it means. Keep the supplier's invoice as proof of expense - the expense remains deductible on ordinary evidence. Watch the RM3 million line as you grow, and re-check your position if your shareholding changes. Service tax on imported taxable services is separate legislation administered by Royal Malaysian Customs, and this exemption does not touch it.
The threshold is recent, and it has moved repeatedly.
| LHDN media release | Businesses exempt below |
|---|---|
| 5 June 2025 | RM500,000 |
| 31 December 2025 | RM1,000,000 |
| 30 August 2026, effective 1 September 2026 | RM3,000,000 |
The most recent change came from the Prime Minister's National Day address on 30 August 2026 and was confirmed by LHDN the same day. We found only a Malay version of that release, which is part of why so much English-language guidance is still out of date - and where a Malay text and an English one differ, the Malay governs.
Careful with LHDN's own phase table. Table 1.1 of the Guideline still shows implementation dates by turnover, ending "up to RM5 million - 1 January 2026". It does not mention the RM3 million exemption, which appears later in the same document at section 1.6.1(e) and overrides it. Reading the table alone produces a confident wrong answer.
Is a small subsidiary still exempt?
Section 1.6.10 of the Guideline, added in version 4.8, removes the exemption in three cases. It does not apply where the taxpayer:
- has a non-individual shareholder with annual turnover or revenue of at least RM3 million;
- is a subsidiary of a holding company with annual turnover or revenue of at least RM3 million; or
- has a related company or joint venture with annual turnover or revenue of at least RM3 million.
This catches a great many small subsidiaries. A two-person company owned by a larger group is inside the mandate no matter how small its own revenue. "Related company" takes its meaning from section 2 of the Promotion of Investments Act 1986 - broadly, common ownership or control between the companies.
When is it due?
A software subscription is an imported service, and imported services have their own deadline. It is not the same as the one for goods, and it is not the "seven days after month end" rule people often quote - that one applies only to consolidated e-Invoices.
| What you bought | Deadline |
|---|---|
| Imported services - software, subscriptions, consulting | End of the month following the month you paid, or received the invoice - whichever came first |
| Imported goods | End of the second month after customs clearance |
| Consolidated e-Invoices, where permitted | Within seven calendar days after month end |
So an invoice received and paid in October would fall due by the end of November. If the invoice arrived in September and you paid in October, the clock starts in September. One self-billed e-Invoice per transaction is the standing rule - see the next section for the relief that currently applies to some taxpayers.
Do not account for the same tax twice. Section 10.4.7 requires service tax on imported taxable services to be included in the self-billed e-Invoice where it applies. But where the foreign supplier is registered with Royal Malaysian Customs and already charges Malaysian service tax on its invoice, the buyer is exempt from accounting for it again. Google charges Malaysian service tax on its Workspace invoices, so for that purchase there is usually nothing to self-account. Check your own supplier's invoice, and check the current rate, which is set by gazetted order rather than by LHDN.
Can I combine a month of invoices into one?
Two answers, and the second is the one that matters right now.
The standing rule is no. Section 3.6.5 states that consolidation does not apply to self-billed e-Invoices, with four exceptions - individuals not conducting a business, interest paid to the public at large, certain insurance payments, and transactions involving a taxpayer's own overseas branches. Foreign suppliers are not among them, and LHDN's General FAQs answer the question directly: a Malaysian buyer cannot consolidate invoices from the same foreign supplier.
The interim relaxation says otherwise, for some taxpayers. Section 16.2(b) allows taxpayers to "issue consolidated self-billed e-Invoice for all self-billed circumstances outlined under Section 8.3" during their relaxation period. That period is set per implementation date in Table 16.1 and is not the same for everyone: the row covering the 1 January 2026 and 1 July 2026 implementation dates runs until 31 December 2027, while the rows above RM5 million expired during 2025.
So whether you may consolidate depends on which row you are in. Find yours in Table 16.1 before relying on it. When the window lapses the standing rule returns: one self-billed e-Invoice per transaction.
What do I put where the supplier has no Malaysian TIN?
A foreign supplier usually has no Malaysian tax identification number, and LHDN publishes fallback values for exactly this situation in Table 10.1 of the Specific Guideline. Enter the supplier's real details wherever you have them. The placeholders below apply only where the information is not available, not provided, or not applicable.
| Field | What to enter for a foreign supplier |
|---|---|
| Supplier TIN | The supplier's TIN where available; otherwise EI00000000030 |
| Registration or passport number | The actual number; NA if not available or not provided |
| SST registration number | The actual number where applicable; otherwise NA |
| MSIC code | The actual code; 00000 if not applicable, not available or not provided |
| Business activity description | The actual description; NA if not available |
| Classification | A three-digit code - required, and easily missed |
The document type is code 11, self-billed invoice. That value comes from the MyInvois SDK e-Invoice type list rather than from Table 10.1.
The commonest mistake. EI00000000030 is the foreign supplier. EI00000000010 is the general public, and EI00000000020 is a foreign buyer. MyInvois validation rejects the wrong one outright, so this is worth getting right first time.
You also do not have to send the finished document to Google. Section 10.4.6 states the Malaysian purchaser "is not obliged to share the self-billed e-Invoice with the Foreign Seller", and LHDN notifies only you. The validated e-Invoice is your proof of expense.
If you get something wrong, there is a 72-hour window from validation to cancel. After that the only remedy is a new credit, debit or refund note e-Invoice.
What happens if you do not do it?
LHDN's General FAQs state that failure to issue an e-Invoice is an offence under section 120(1)(d) of the Income Tax Act 1967, carrying "a fine of not less than RM200 and not more than RM20,000 or imprisonment not exceeding 6 months or both, for each non-compliance".
Two things soften that as things stand. Section 16.3 of the Specific Guideline records that LHDN "will not undertake any prosecution action under Section 120 of the Income Tax Act 1967 during the interim relaxation period" - but only "provided that taxpayers comply with the requirements mentioned under Section 16.2", and that proviso is the whole substance of it. Separately, LHDN is running an e-Invoice Special Voluntary Disclosure Programme from 7 July 2026 to 31 December 2027, under which compliance reviews and enforcement are not undertaken for the e-Invoices disclosed - though that relief does not apply where a disclosure involves fraud, wilful default or negligence.
Prosecution is the headline risk and the remote one. The likelier exposure is ordinary: an expense questioned on audit with no valid document to support it.
Is there a way to avoid it entirely?
For most foreign software, no. If you buy Adobe, Canva or AWS from abroad and you are inside the mandate, you self-bill.
Google Workspace is different only because it can be bought from a Malaysian supplier. The self-billing duty is triggered by the supplier being foreign, so our reading is that buying through a Malaysian reseller would leave you with an ordinary e-Invoice and nothing to self-bill.
Our reading, not an LHDN ruling, and not tax advice. It follows from how LHDN defines a supplier and from section 10.4.3, but LHDN publishes nothing on resellers of foreign software that we could find. It assumes the reseller is the supplier of record rather than your agent - the invoice and the contract will tell you which yours is. We sell Google Workspace, so we have a commercial interest in this reading. Put it to your tax agent before relying on it.
Be clear about the size of this. If your turnover is under RM3 million you have nothing to self-bill in the first place, and this changes nothing for you. If you are inside the mandate it removes one document for one subscription - you would still self-bill for any other foreign software you buy, and while your relaxation window is open those can be consolidated into a single monthly document anyway. It is a piece of admin removed, not a compliance problem solved.
Office Niaga sells Google Workspace at Google's list price for the subscription, in Ringgit, plus a one-off RM100 setup fee on your first order and 8% SST. We issue a Malaysian tax invoice for every payment and submit a MyInvois e-invoice for validation. Further detail is on our MyInvois page, and Google Workspace pricing in Ringgit sets out the figures. If you already have a subscription, transferring your reseller does not change your mailboxes, domain or data.
Sources
Every claim above comes from one of these, and each is quoted with its version and date because LHDN overwrites the files in place.
- e-Invoice Guideline, version 4.8, 30 August 2026 - the exemption at 1.6.1(e) and its conditions at 1.6.10
- e-Invoice Specific Guideline, version 4.9, 7 September 2026 - self-billing at section 8, cross-border at section 10, consolidation at 3.6.5, the relaxation at section 16
- e-Invoice General FAQs, updated 4 September 2026
- LHDN media release, 30 August 2026, on raising the threshold to RM3 million
- Income Tax Act 1967, sections 82C and 120
All are published at hasil.gov.my. LHDN revises these documents roughly monthly, so check the current version before acting.
Office Niaga is an authorised Google Workspace reseller in Malaysia, operated by Web Impian Sdn. Bhd. We are not tax agents, accountants or licensed tax advisers. This page summarises LHDN's published guidelines as at 23 September 2026 for general information only. It is not tax advice and must not be relied on as such - LHDN revises these documents roughly monthly, and this page may no longer reflect the current version. For your own position, speak to a licensed tax agent or check hasil.gov.my.
