Question: Referring to LHDN – general FAQs .
I am in the car retailer industry, would like to understand more on Question 41 (as highlighted-item no. 2) in regard to refund note – overpayment refund to customer.
Our current situation is as follow:
– Initial Invoice value at RM40,000.00 (all in price)
Customer paid booking fee RM500.00
Customer apply full loan amount RM45,000.00, so sales e-invoice amount revised to same loan amount
Bank approved loan amount RM40,500.00 & disbursed to company
In this case, we issue a credit note of RM5,000 to reduce the invoice value to RM40,000.00
Payment received total RM41,000.00:
a) from bank RM40,500.00
b) from customer RM500.00 as booking fee
Therefore excess payment of RM1,000.00
My question is the refund of RM1,000 need to issue REFUND NOTE? For the same scenario, can credit note & refund note apply to the same e-invoice?
Answer: Based on the FAQ document and e-Invoice Specific Guideline, let me analyze your case:
1. According to FAQ #41, a refund note e-Invoice is NOT required for:
– Payment made wrongly by buyers
– Overpayment by buyers
– Return of security deposits
2. In your scenario:
– Original sale value: RM40,000
– But issue e-invoice to match loan application: RM45,000
– Final adjusted amount (after credit note): RM40,000
– Total payments received: RM41,000 (RM40,500 from bank + RM500 booking fee)
– Excess amount: RM1,000
3. Analysis:
– Credit Note: You correctly issued a credit note for RM5,000 to adjust the invoice value back to RM40,000
– Refund of RM1,000: This falls under “overpayment by buyers” category since it resulted from the bank disbursing more than the final invoice amount
– Therefore, you do NOT need to issue a refund note e-Invoice for the RM1,000 refund
4. Regarding your question about applying both credit note and refund note to the same e-Invoice:
– Yes, technically you can have both credit notes and refund notes referring to the same original e-Invoice
– However, in your specific case, you only need the credit note since the refund falls under the overpayment exception
Best practice recommendation:
1. Keep proper documentation of:
– Original e-Invoice
– Credit note e-Invoice for the RM5,000 adjustment
– Proof of payments received
– Proof of refund made
2. No refund note e-Invoice is required for the RM1,000 overpayment refund as it falls under the exception category.
