When Should You Self-Bill e-Invoice?
- Chow Ping
- Aug 14
- 3 min read
Your supplier forgot to send you an e-Invoice.
Does that mean you have to make one for them?
Not necessarily.
According to LHDN, you're only required to issue a Self-Billed e-Invoice if your payment falls under a specific category called "Special Payments."
What exactly is a "Special Payment"?
Normally, whoever sells you something is the one who issues the e-Invoice. That's the default flow.
But LHDN identified 9 specific scenarios where the normal flow doesn't work.
Maybe the "seller" is an individual with no business registration. Maybe they're overseas and outside LHDN's reach. Maybe it's not really a sale at all, just a payout or a claim.
In these 9 scenarios, the responsibility flips. You, the payer, become the one who has to issue the invoice on their behalf.
LHDN calls these Special Payments. If your situation falls under one of these categories, you have to self-bill e-Invoice.
Without further ado, here are the 9 situations where a Self-Billed e-Invoice is required.
The 9 situations that require a Self-Billed e-Invoice
1. Incentives or commissions
Are you paying out incentives or commissions?
Is the person receiving it an agent, dealer, or distributor?
If yes to both, you need to self-bill.
Example: You run an insurance agency. You pay your agents commission every time they close a policy. That commission payment needs a self-billed e-Invoice.
2. Importing goods or services
If you're paying a supplier based outside Malaysia, or have goods or services coming into Malaysia, this counts as a Special Payment.
Example: Your business imports raw materials from a supplier in Vietnam. Since the Vietnamese supplier isn't registered under Malaysia's e-Invoice system, you're the one who has to issue the e-Invoice.
3. Profit distribution or dividends
Are you distributing profits to shareholders or investors?
Here's the catch: dividends paid out by companies (your Sdn Bhd or Bhd) are currently exempt from this rule.
But other forms of profit distribution outside of standard company dividends may still require a self-billed e-Invoice. When in doubt, check with your accountant.
Don't have one? You're in luck, because that's what we do!
4. E-commerce platform fees
If you sell on Shopee, Lazada, or similar platforms and pay them fees, these platform fees fall under Special Payments too.
If you're the platform operator paying out to merchants or delivery riders, the same rule applies in reverse. You'll need to self-bill for those payouts.
5. Lottery or gaming winnings
Are you a licensed lottery or gaming operator? Are you paying out winnings to a lucky winner?
If yes, you need to issue a self-billed e-Invoice to that winner. They're not going to invoice you for winning, so the responsibility falls on you.
6. Payments to individuals not running a business
Take note if you are paying someone who isn't operating as a registered business.
Common examples:
Rental payments to a private individual landlord
Referral fees paid to a salaried employee (not a registered freelancer)
Since these individuals aren't set up to issue e-Invoices themselves, you'll need to do it for them.
7. Interest payments
Are you paying interest to someone?
If the recipient is a licensed bank or financial institution, they'll issue their own e-Invoice.
But if you're paying interest to an individual or another company (say, an inter-company loan), that responsibility lands on you.
8. Insurance claims
If you are an insurance company paying out a claim, it doesn't matter whether the person receiving the payout is an individual or a business.
Insurance claim payouts always require a self-billed e-Invoice from the insurer's side.
9. Capital reduction or share buybacks
Are you returning capital back to your shareholders or investors?
This includes share buybacks and formal capital reduction exercises.
These transactions count as Special Payments, so you'll need to self-bill accordingly.
What if none of these apply to you?
Then breathe easy. If your payment doesn't fall into one of the 9 categories above, you're not required to issue a self-billed e-Invoice. Your supplier not sending you an invoice isn't automatically your problem to fix.
Use the time to play with your kids instead.
If you want even more time with your kids, instead of worrying about paperwork and compliance? That's what we're here for.
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