e-Invoicing in Malaysia: Here are some MUST KNOW Questions and Answers

Published: 8 May 2025

With the mandatory rollout of e-Invoicing in Malaysia, businesses are adapting quickly to ensure full compliance.

Today, we address two very important and practical questions that we get asked very often by our clients:

1. Who holds the legal responsibility for e-Invoice submissions?
2. How to handle supplier information for foreign transactions?

1. Who is legally responsible if something goes wrong with e-Invoice submissions?

Let’s set the scene:
Your company director appoints you — an employee or external representative — to handle e-Invoice submissions through the MyInvois portal.

You log in with your personal IC number and password to prepare, sign, and submit the e-Invoices.

Naturally, the question arises: If something goes wrong and penalties or imprisonment are involved, who will be responsible?

Here’s the key point:

✅ Under Section 75A of the Income Tax Act 1967 (ITA), the company’s director is ultimately responsible for any tax due or debts owed by the company.

✅ This means if your company fails to comply with tax obligations — including e-Invoicing requirements that lead to tax underreporting or non-payment — the director, not the appointed representative, bears the legal responsibility.

In short:

• The appointed representative (you) is not personally liable for penalties like fines or imprisonment under the Income Tax Act, unless you were personally involved in fraud or misconduct.
• The director(s) will be held accountable for any non-compliance or outstanding tax debts.
• However, if a criminal element like deliberate fraud is found, IRBM (Inland Revenue Board of Malaysia) may still investigate individuals involved.

Always Remember:
Even if you are not personally liable, always ensure proper records, documentation, and careful submission.

Protect yourself by keeping written authorization from the company and detailed logs of the submissions you handle.

*A written authorization is an official document that gives someone the legal authority to act on behalf of another individual or organization. It serves as a means of delegating responsibility, enabling the authorized person to carry out certain tasks or make decisions that would typically fall under the authority of the one granting the permission.*

✅ 2. What Business Registration Number to Use When Purchasing Goods from a Foreign Supplier?

With globalization, it’s common for Malaysian businesses to purchase goods and services from overseas suppliers.

But what happens when the foreign supplier doesn't have a Malaysian business registration number?

Here’s what the e-Invoice Specific Guideline says:

✅ If the foreign seller does not have a business registration number (or doesn’t provide one), Malaysian purchasers input is "NA" (Not Available) in the self-billed e-Invoice.

Therefore you can key in the following if the foreign seller does not have a business registration number:

• Supplier's Registration Number = "NA"
• Supplier’s Tax Identification Number (TIN) = "NA" if not applicable or not provided.

This simple step ensures that your self-billed e-Invoice submission remains valid and compliant with IRBM requirements, even when dealing with foreign vendors.

Always Remember:
Document communications with foreign suppliers. If the supplier states that they do not have a business registration number, keep a copy of their confirmation for your records in case of future audits.

✅ Moving Forward with e-Invoicing

E-Invoicing is a major shift, but with the right knowledge and good practices, businesses can manage it smoothly and stay on the right side of the law.

✅ Directors remain legally responsible under Section 75A of the ITA — not the appointed representatives, in general.

✅ For foreign suppliers without business registration numbers, simply enter "NA" in the relevant e-Invoice fields.

We are committed to helping businesses navigate the e-Invoice landscape with clarity, compliance, and confidence.