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| Understanding the e-Invoicing Obligation in Donation and Contribution Requirements in Malaysia |
| https://anusaar.com/blogs/understanding-the-e-invoicing-obligation-in-donation-and-contribution-requirements-in-malaysia/ |
| As Malaysia accelerates its transition toward a nationwide electronic invoicing system, organisations across sectors are reviewing how the new framework applies to their specific operations—including the handling of donations and contributions. For non-profits, religious bodies, and charitable institutions, this is particularly important to ensure compliance with the evolving regulations under the Income Tax Act 1967 and the LHDN e-Invoice Guideline. One critical area to focus on is the e-invoicing obligation in donation scenarios.
In this article, we outline the key e-invoicing obligation in donation and contribution cases, based on the latest guidance issued by the Inland Revenue Board of Malaysia (LHDN).
1. Are e-Invoices Required for Donations or Contributions?
Yes, e-Invoices—whether individual or consolidated—must be issued for donations or contributions received, with the following exceptions:
Religious institutions or organisations established exclusively for the purpose of worship or advancing religion.
Other entities receiving non-tax-exempt donations or contributions under the Income Tax Act 1967.
However, this exemption does not apply if the religious organisation:
Is an approved institution or fund under subsections 44(6), 44(6B), 44(11B), 44(11C), or 44(11D); or
Manages a charity/community project approved under paragraph 34(6)(h).
Such organisations are still required to issue e-Invoices for the donations received, thereby falling under the e-invoicing obligation in donation rules.
2. Treatment of Monetary Donations
Monetary contributions—regardless of the payment method (cash, cheque, bank transfer, etc.)—require e-Invoice issuance:
If a donor requests an e-Invoice: an individual e-Invoice must be issued.
If no request is made: a consolidated e-Invoice must be issued within 7 calendar days after month-end, covering all relevant transactions.
This reinforces the e-invoicing obligation in donation transactions, even when donors do not explicitly ask for documentation.
Refer to Sections 3.5 and 3.6 of the LHDN e-Invoice Specific Guideline for technical instructions.
3. Donations-in-Kind
For donations-in-kind (i.e., non-monetary items such as goods or services), no e-Invoice is required. This is an exception to the e-invoicing obligation in donation scenarios, where monetary value is not directly involved.
4. Donor’s Obligation to Self-Issue e-Invoices
Donors are not required to issue self-billed e-Invoices for donations or contributions made to organisations that are not tax-exempt under the Income Tax Act 1967. However, understanding when e-invoicing obligation in donation applies to recipient organisations remains crucial.
5. Religious Institutions Involved in Other Activities
Religious institutions or organisations managing places of worship are not required to issue e-Invoices for donations received.
However, if they engage in commercial activities, such as the sale of goods or provision of services, they must issue e-Invoices for those transactions.
Even in hybrid operational models, knowing the boundaries of the e-invoicing obligation in donation versus business income is essential for compliance.
6. Self-Billed e-Invoices for Imports and Foreign Services
Organisations, including those not approved for tax exemption, must issue self-billed e-Invoices for:
Imported goods, or
Services acquired from foreign suppliers,
if the criteria under Section 8.3 of the e-Invoice Guideline apply.
7. Obligation to Provide Buyer Information to Suppliers
Where a transaction involves activities for which consolidated e-Invoices are not allowed—such as purchase of motor vehicles, construction services, or materials—all buyers, regardless of tax-exempt status, are required to provide their identification details to the supplier.
8. Business Registration Number (BRN) for e-Invoice and TIN Purposes
Entities registered with any of the following can use their official registration number as their BRN when registering for a Tax Identification Number (TIN) or issuing e-Invoices:
Registrar of Societies (ROS)
Companies Commission of Malaysia (SSM)
Legal Affairs Division of the Prime Minister’s Department (BHEUU)
Other recognised regulatory bodies in Malaysia
Final Remarks
As e-Invoicing becomes a cornerstone of Malaysia’s digital tax landscape, it is essential for all types of organisations—including those receiving donations—to understand their responsibilities. Proper knowledge of the e-invoicing obligation in donation will ensure transparency, accountability, and alignment with LHDN’s broader digital transformation goals.
If your organisation is impacted and you require guidance on e-Invoice implementation, feel free to reach out to our team of tax technology specialists.
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| Sport Fishing in Andaman for Chinese Anglers |
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| Kaleeyantey Law Firm |
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| Kaleeyantey Law Firm is a full-service legal practice with offices in CBD Belapur, Navi Mumbai, offering expert legal solutions across civil, criminal, corporate, family, property, and intellectual property law. Our experienced team of lawyers in Navi Mumbai provides litigation and non-litigation services, including contract drafting, title verification, and regulatory compliance. |
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