Based on the latest FAQ (version 4.6 dated 10 December 2025)
Question 92: What are the Determinants for the Implementation of e-Invoice for MSMEs?
This question addresses how MSMEs should determine whether they’ve reached the RM1 million threshold that triggers the e-Invoice implementation requirement.
The answer provides three clear methods for making this determination.
The Three Methods of Determination
The implementation of e-Invoice applies to taxpayers with an annual turnover or revenue of at least RM1 million, determined as follows:
Method A: Taxpayers with Audited Financial Statements
Basis: Annual turnover or revenue stated in the statement of comprehensive income in the audited financial statements for the relevant year.
Who Uses This:
- Companies required by law to prepare audited financial statements
- Larger businesses that prepare audited accounts
- Entities with proper accounting systems and external auditors
What to Look For:
Look at your Statement of Comprehensive Income (previously called the Profit and Loss Statement) in your audited financial statements.
The revenue or turnover figure at the top of this statement is what you use to determine if you’ve reached RM1 million.
Example – ABC Trading Sdn Bhd:
ABC Trading Sdn Bhd closes its accounts on 31 December each year and prepares audited financial statements.
Audited Financial Statements for Year Ended 31 December 2026:
Statement of Comprehensive Income shows:
- Revenue from the sale of goods: RM1,350,000
- Other income: RM50,000
- Total Revenue: RM1,400,000
Determination:
ABC Trading has exceeded RM1 million based on the revenue figure in its audited statement of comprehensive income.
Implementation Date:
1 January 2028 (second year following YA2026)
Key Point:
Use the revenue/turnover figure from the audited financial statements, not the profit figure. Revenue is the gross income before deducting expenses.
Method B: Taxpayers without Audited Financial Statements
Basis: Annual revenue reported in the tax return for the year of assessment for the relevant year.
Who Uses This:
- Sole proprietors who don’t prepare audited accounts
- Small businesses not required to audit their accounts
- Partnerships without audited statements
- Any business that files tax returns but doesn’t prepare audited financial statements
What to Look For:
Check your income tax return form (Form B for companies, Form BE for individuals conducting business).
Look at the gross business income or revenue figure you reported to IRBM.
Example – Encik Rashid’s Trading Business:
Encik Rashid operates a sole proprietorship business called Rashid Enterprise.
He does not prepare audited financial statements but files his annual income tax return.
Tax Return (Form BE) for Year of Assessment 2026:
Section on Business Income shows:
- Gross business income: RM1,180,000
Determination:
Rashid Enterprise has exceeded RM1 million based on the gross business income reported in the tax return.
Implementation Date:
1 January 2028 (second year following YA2026)
Important Note:
Use the gross business income figure (before deducting expenses), not the adjusted income or chargeable income.
Method C: Taxpayers with Annual Turnover/Revenue of At Least RM1 Million
Basis: Taxpayers with annual turnover or revenue of at least RM1 million for the relevant year.
Who Uses This:
- Any taxpayer, regardless of whether they have audited statements or not
- Businesses that can determine their annual turnover from their own records
- Companies that track their revenue regularly
What to Look For:
Your actual annual turnover or revenue based on your business records, accounting system, sales records, or any reliable documentation of your income.
Example – Kedai Berkat Gemilang (From Official FAQ):
Kedai Berkat Gemilang recorded product sales income of RM1.2 million as of 31 December 2026.
Analysis:
In view that the total sales income earned has reached RM1 million, Kedai Berkat Gemilang is required to implement e-Invoice starting from 1 January 2028.
Key Point:
This method allows businesses to use their own records to determine if they’ve reached the threshold, even without formal audited statements or tax returns.
Understanding “Annual Turnover or Revenue”
What IS Included:
Sales of Goods:
- All revenue from selling products
- Wholesale sales
- Retail sales
- Online sales
Service Income:
- Professional fees
- Consultation charges
- Service fees
- Commission income
Trading Income:
- Revenue from trading activities
- Import/export sales
Other Business Income:
- Rental income from business property
- Franchise fees received
- Royalties from business operations
What is NOT Included:
Non-Operating Income:
- Interest income from bank deposits
- Dividend income from investments
- Gains from the sale of fixed assets
- Windfall gains
Capital Receipts:
- Loans received
- Capital contributions
- Proceeds from the sale of business assets
Important Distinction: Use your gross business revenue/turnover (before expenses), not your net profit.
Practical Application Scenarios
Scenario 1: Company with Audited Statements
Modern Electronics Sdn Bhd:
- Prepares audited financial statements annually
- Year-end: 31 March
For YA2026 (1 April 2025 to 31 March 2026):
Audited Statement of Comprehensive Income shows:
- Revenue from sales: RM950,000
- Other operating income: RM80,000
- Total Revenue: RM1,030,000
Determination Method:
Method A (Audited Financial Statements)
Result: Exceeded RM1 million threshold
Implementation Date: 1 January 2028
Scenario 2: Sole Proprietor without Audited Statements
Puan Aminah – Beauty Salon:
- Operates as sole proprietor
- Does not prepare audited accounts
- Files Form BE annually
For YA2026:
Tax Return Form BE shows:
- Gross income from beauty services: RM880,000
- Rental income from shop lot: RM40,000 (personal rental, not business)
- Total Business Income: RM880,000
Determination Method: Method B (Tax Return)
Result: Below RM1 million threshold
Status: Exempted (if meets other exemption criteria)
Scenario 3: Business Using Own Records
Warung Pak Hassan – Restaurant:
- Tracks daily sales in the cash register
- Maintains simple bookkeeping
- No audited accounts, hasn’t filed tax return yet for 2026
For YA2026:
Own records show:
- Total sales from January to December 2026: RM1,150,000
Determination Method: Method C (Own Records)
Result: Exceeded RM1 million threshold
Implementation Date: 1 January 2028
Note: Even without audited statements or a tax return filed yet, Pak Hassan can determine from his own records that he’s exceeded the threshold.
Which Method Should You Use?
Priority Order:
If you have audited financial statements: Use Method A
- This is the most formal and official record
- Preferred by IRBM for verification purposes
- Provides the clearest documentation
If you don’t have audited statements but file tax returns: Use Method B
- Tax returns are official documents submitted to IRBM
- Reliable and verifiable source
- Commonly used by sole proprietors and small businesses
If you track your own revenue: Use Method C
- Use your business records
- Useful for advanced planning
- Allows you to anticipate when you’ll reach the threshold
Important Clarifications
Clarification 1: Use Gross Revenue, Not Net Profit
Many businesses confuse revenue with profit.
Here’s the difference:
Revenue/Turnover: RM1,200,000 (this is what you measure)
Less: Expenses: RM900,000
Net Profit: RM300,000 (don’t use this figure)
For e-Invoice threshold: Use the RM1,200,000 figure, not the RM300,000.
Clarification 2: The “Relevant Year” Means the Year You’re Checking
For businesses starting from YA2026 onwards, the relevant year is whichever year you’re checking to see if you’ve exceeded the threshold.
Example:
- Checking if you exceeded in YA2026? Look at YA2026 revenue.
- Checking if you exceeded in YA2027? Look at YA2027 revenue.
- Each year is evaluated independently.
Clarification 3: What If You Have Both Audited Statements AND Tax Returns?
If you have both, use your audited financial statements (Method A) as the primary source, because:
- They’re more detailed and comprehensive
- They’re prepared by professional accountants
- They’re verified by external auditors
- They’re the most reliable source
However, normally, your tax return revenue should match your audited statement revenue, so there shouldn’t be a significant difference.
Special Situations
Situation 1: Mid-Year Business Commencement
New Business Starting 1 July 2026:
Revenue from 1 July to 31 December 2026: RM800,000
Question: Is this RM800,000 considered to have exceeded RM1 million?
Answer: No. This is only 6 months of operation.
The revenue would need to be annualised, or you would wait to see the full year’s revenue in YA2027.
Situation 2: Multiple Revenue Streams
Business with Multiple Income Sources:
- Product sales: RM600,000
- Service income: RM350,000
- Commission income: RM180,000
- Total: RM1,130,000
Determination: Add ALL business revenue streams together.
The total is RM1,130,000, which exceeds RM1 million.
Situation 3: Seasonal Business
Tour Company – Highly Seasonal:
- Peak season (3 months): RM900,000
- Off-season (9 months): RM150,000
- Annual Total: RM1,050,000
Determination: Use the full annual figure of RM1,050,000, regardless of seasonal fluctuations.
Record-Keeping Recommendations
To properly determine your revenue threshold:
Keep Proper Records:
- Sales invoices and receipts
- Cash register records
- Bank statements showing deposits
- Accounting software records
Regular Monitoring:
- Track your revenue monthly
- Maintain running totals
- Project year-end figures
Documentation:
- Keep audited financial statements if prepared
- Retain copies of tax returns
- Maintain supporting documentation
Professional Help:
- Consider engaging an accountant
- Get professional advice on revenue calculation
- Ensure proper classification of income
问题92：中小微企业实施电子发票的确定标准是什么?
此问题解决中小微企业应如何确定是否达到触发电子发票实施要求的100万令吉门槛。
答案提供了三种明确的确定方法。
三种确定方法
电子发票的实施适用于年营业额或收入至少100万令吉的纳税人，确定方法如下:
方法A：拥有审计财务报表的纳税人
依据：相关年度审计财务报表中综合收益表所列的年营业额或收入。
谁使用:
- 法律要求准备审计财务报表的公司
- 准备审计账目的较大企业
- 拥有适当会计系统和外部审计师的实体
查看内容:
查看您审计财务报表中的综合收益表(以前称为损益表)。
此报表顶部的收入或营业额数字是您用来确定是否达到100万令吉的数字。
方法B：没有审计财务报表的纳税人
依据：相关年度评估年度税务申报表中报告的年收入。
谁使用:
- 不准备审计账目的独资经营者
- 不需要审计账目的小企业
- 没有审计报表的合伙企业
- 提交税务申报但不准备审计财务报表的任何企业
查看内容：
检查您的所得税申报表(公司为B表,个人经营业务为BE表)。
查看您向IRBM报告的总营业收入或收入数字。
方法C：年营业额/收入至少100万令吉的纳税人
依据：相关年度年营业额或收入至少100万令吉的纳税人。
谁使用:
- 任何纳税人,无论是否有审计报表
- 可以从自己记录中确定年营业额的企业
- 定期跟踪收入的公司
查看内容:
根据您的业务记录、会计系统、销售记录或任何可靠的收入文档确定的实际年营业额或收入。
重要澄清
澄清1：使用总收入，而非净利润
许多企业将收入与利润混淆。
区别如下:
收入/营业额：120万令吉(这是您要衡量的)
减:费用：90万令吉
净利润：30万令吉(不要使用这个数字)
用于电子发票门槛：使用120万令吉数字，而非30万令吉。
记录保存建议
为了正确确定您的收入门槛:
保持适当的记录:
- 销售发票和收据
- 收银机记录
- 显示存款的银行对账单
- 会计软件记录
定期监控:
- 每月跟踪您的收入
- 维护累计总额
- 预测年终数字
文档:
- 保留准备的审计财务报表
- 保留税务申报表副本
- 维护支持文档
专业帮助:
- 考虑聘请会计师
- 获得有关收入计算的专业建议
- 确保正确分类收入
#看趋势看财税看CCS
