For Malaysian importers, managing self-billed e-Invoices can be complex, especially when goods are delivered across multiple shipments under a single invoice from a foreign supplier.
The question many importers ask is:
"When do we need to issue the self-billed e-Invoice, and for which shipments?"
This guide explains the rules surrounding self-billed e-Invoices in a clear and professional manner. By addressing three common scenarios, you will gain a comprehensive understanding of when and how to issue self-billed e-Invoices in compliance with customs and tax regulations.
What is a Self-Billed e-Invoice?
A self-billed e-Invoice is an invoice issued by a Malaysian buyer (importer) on behalf of a foreign supplier for imported goods.
It is a mandatory requirement that importers must issue the self-billed e-Invoice by the end of the month following the month in which customs clearance is obtained. This ensures proper reporting of import transactions and aligns with the Royal Malaysian Customs Department (RMCD) guidelines.
Three Scenarios for Issuing Self-Billed e-Invoices
Scenario 1: Supplier’s Invoice Issued Before the First Shipment Clearance
If the foreign supplier issues the invoice before the first shipment clears customs, the Malaysian buyer must:
- Issue one self-billed e-Invoice for the first shipment clearance.
- No additional self-billed e-Invoices are required for the subsequent shipments under the same invoice.
Example:
Shipment |
Supplier Invoice Issue Date |
Customs Clearance |
Self-Billed e-Invoice |
Shipment 1 |
1 January 2025 |
10 January 2025 |
Yes |
Shipment 2 |
1 January 2025 |
12 March 2025 |
No |
Shipment 3 |
1 January 2025 |
30 September 2025 |
No |
Shipment 4 |
1 January 2025 |
16 December 2025 |
No |
Key Takeaway: Only one self-billed e-Invoice is required when the supplier’s invoice is issued before the first shipment clearance.
Scenario 2: Supplier’s Invoice Issued After the First Shipment Clearance
If the supplier issues the invoice after the first shipment has cleared customs, the Malaysian buyer must:
- Issue a self-billed e-Invoice for each shipment as it clears customs till supplier’s invoice is received.
- Once the supplier’s invoice is received, issue a final self-billed e-Invoice to align the amounts declared.
Example:
Shipment |
Supplier Invoice Issue Date |
Customs Clearance Date |
Self-Billed e-Invoice |
Shipment 1 |
1 January 2025 |
10 January 2025 |
Yes |
Shipment 2 |
1 January 2025 |
12 March 2025 |
No |
Shipment 3 |
1 January 2025 |
30 September 2025 |
No |
Shipment 4 |
1 January 2025 |
16 December 2025 |
No |
Final Invoice Issuance:
- When the supplier issues the invoice on 1 October 2025, the buyer must issue a final self-billed e-Invoice to reconcile the total amount.
Key Takeaway: Self-billed e-Invoices must be issued for each shipment cleared before the supplier’s invoice is received. A final self-billed e-Invoice ensures consistency with the supplier’s declared amounts.
Scenario 3: Supplier’s Invoice Issued After the Final Shipment Clearance
If the supplier issues the invoice only after all shipments have cleared customs, the Malaysian buyer must:
Issue a self-billed e-Invoice for each shipment as it clears customs.
Once the supplier’s invoice is issued, a final self-billed e-Invoice is required if there is a discrepancy in the total declared value; if there is no discrepancy there is no need for a final self-billed e-Invoice.
Example
Shipment |
Supplier Invoice |
Customs Clearance |
Self-Billed e-Invoice |
Shipment 1 |
Not issued |
10 January 2025 |
Yes |
Shipment 2 |
Not issued |
12 March 2025 |
Yes |
Shipment 3 |
Not issued |
30 September 2025 |
Yes |
Shipment 4 |
Not issued |
16 December 2025 |
Yes |
Final Invoice |
31 December 2025 |
N/A |
Yes, if total differ |
Key Takeaway: Self-billed e-Invoices must be issued for each shipment cleared. A final self-billed e-Invoice must be issued if the total declared value differs from the supplier’s invoice.
Summary of Scenarios
Scenario |
Supplier Invoice issuing Time |
Self-Billed e-Invoice |
Scenario 1 |
Before first shipment clearance |
Issue for the first shipment only. |
Scenario 2 |
After first shipment clearance |
Issue for each shipment till invoice is received + Final self-billed e-Invoice after receiving invoice. |
Scenario 3 |
After final shipment clearance |
Issue for each shipment + Final self-billed e-Invoice if needed. |
Compliance Tips for Malaysian Importers
To remain compliant and avoid penalties:
Maintain Accurate Records: Track the supplier invoice date, shipment clearances, and customs forms.
Timely Issuance: Issue self-billed e-Invoices by the end of the month following the month of customs clearance.
Customs References: Include the customs form reference number (e.g., Customs Form No. 1) in all self-billed e-Invoices.
Reconcile Totals: Ensure the total amount declared aligns with the supplier’s final invoice.
Conclusion
For Malaysian importers handling multiple shipments under one foreign supplier invoice, understanding when to issue self-billed e-Invoices is essential.
Whether the supplier’s invoice is issued before, during, or after customs clearances, following the rules ensures compliance with RMCD regulations and smooth business operations.
By issuing self-billed e-Invoices on time and reconciling values accurately, importers can avoid unnecessary delays and penalties.
Frequently Asked Questions
When should a self-billed e-Invoice be issued if the supplier’s invoice is issued before the first shipment?
If the supplier’s invoice is issued before the first shipment, a self-billed e-Invoice should be issued after the first RMCD clearance. No further self-billed e-Invoices are needed for subsequent shipments under the same supplier’s invoice.
What happens if the supplier’s invoice is issued after the first shipment’s RMCD clearance?
In this case, a self-billed e-Invoice must be issued for each shipment based on the RMCD clearance. Additionally, a final self-billed e-Invoice must be issued once the supplier’s invoice is available, making sure the total tallies.
What if the supplier’s invoice is issued only after the final shipment?
A self-billed e-Invoice should be issued for each shipment as per the RMCD clearance. After the final shipment, an additional self-billed e-Invoice should be issued if the supplier’s invoice total differs from the total of the self-billed invoices.
Are customs form numbers required in self-billed e-Invoices?
Yes, customs form reference numbers (e.g., Customs Form No. 1) must be included in the relevant self-billed e-Invoice for compliance.
What is the deadline for issuing a self-billed e-Invoice?
A self-billed e-Invoice must be issued by the end of the month following the RMCD clearance or the issuance of the supplier’s invoice, whichever applies.