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 e-Invoicing for freelancer with foreign clients, Difference in the MYR-equivalent

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TSKingArthurVI
post Apr 21 2025, 12:24 PM, updated 3d ago

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Hey guys, I'm a freelancer working with foreign clients (mainly in the US). I'm under phase 3 implementation, which means I need to start using the MyInvois portal starting from 1st of July 2025.

I usually invoice them in USD, then they pay me via Wise. According to LHDN's guidelines, I should create an e-Invoice in the USD currency and pick an exchange rate from a platform of choice to use.

The problem is that Wise charges some amount of conversion fee that I absorb. So for example if I invoice $1,000 at exchange rate of 4.4, I don't get RM4,400, I get something like RM4,350 because of RM50 conversion fee from Wise. So how do I tally these amounts? Or is the MYR equivalent not a big deal for an invoice issued in foreign currency because of conversion fluctuations?

The way I see it, there are a couple of options:

1. I invoice as usual using my own format, then once I know the final amount after Wise transfer is in, I create the e-Invoice after the fact with the final amount.

The problem here is I'm not sure that this is allowed.

2. I invoice using e-Invoice, then after the Wise transfer is in, I revise the MYR equivalent amount in the e-invoice via debit/credit note.

This seems to be the sanctioned/approved option, but it's obviously twice the amount of paperwork on my end rclxub.gif

3. I invoice using e-Invoice and don't care that there's a mismatch between my estimated MYR vs. the actual MYR amount that I receive.

This is the least amount of work for me, and it'd be nice if this is indeed acceptable because it's only natural to expect foreign exchange rates to fluctuate a little bit after issuance of e-Invoice.

EDIT: I received an email response from LHDN. We don't have to do anything special.

QUOTE
As mentioned in the Specific Industry FAQ – Financial Services, Section A, Item 16, any foreign exchange gain or loss (whether realised or unrealised) does not require the issuance of an e-Invoice.
Since a foreign payer cannot issue a self-billed e-Invoice, the obligation remains with the Malaysian taxpayer to issue the e-Invoice to the foreign payer.

In your case, you should issue the e-Invoice based on the invoiced amount (in MYR equivalent at the exchange rate on the invoice date), without adjusting for the Wise fee or any exchange loss.
The difference caused by the Wise platform fee is considered a normal business expense or foreign exchange loss and does not require a separate e-Invoice.
This post has been edited by KingArthurVI: Apr 28 2025, 02:15 PM
TSKingArthurVI
post Apr 21 2025, 12:43 PM

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QUOTE(il0ve51 @ Apr 21 2025, 12:31 PM)
just add currency conversion to cost then can minus off the orgnal bll amount to tally wth amout received
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How to do so? Is it via the debit/credit note mechanism?
TSKingArthurVI
post Apr 22 2025, 12:59 PM

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QUOTE(purplefellow @ Apr 22 2025, 10:41 AM)
Interested to know as well since I'm in the same shoes as you. But just a heads up, e-invoice phase 3 has been delayed to Jan 1, 2026.
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I sent an email to LHDN and will update here if I hear back.

So dumb, they delayed phase 3 to 2026 but didn't bother to change it in their email communication which I just received 5 days ago.

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TSKingArthurVI
post Apr 22 2025, 01:01 PM

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QUOTE(purplefellow @ Apr 22 2025, 10:41 AM)
Interested to know as well since I'm in the same shoes as you. But just a heads up, e-invoice phase 3 has been delayed to Jan 1, 2026.
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Actually, we're still on the hook. https://www.hasil.gov.my/en/e-invoice/imple...ation-timeline/ still shows "Taxpayers with an annual turnover or revenue of more than RM500,000 and up to RM25 million" as 1 July... rclxub.gif
TSKingArthurVI
post Apr 22 2025, 03:40 PM

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QUOTE(purplefellow @ Apr 22 2025, 01:37 PM)
My bad! I fall under the SME below RM500k income, which was the ones that got delayed. I'm hoping my accountant will help me sort it out when the time comes  rclxub.gif
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Wow you have an accountant? Can you let me know if they have any updates for you regarding this e-invoicing thing with foreign currency transactions? Thanks in advance thumbup.gif
TSKingArthurVI
post Apr 24 2025, 08:00 PM

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QUOTE(tzxsean @ Apr 22 2025, 10:09 PM)
should check this out https://www.hasil.gov.my/media/acil1u20/spe...-unit-trust.pdf

Item 11 should provide some guidance
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Hmm it's a bit different, because in that case the banks need to invoice the remittance entity like Wise or UnionPay etc., but in my case how can I ask for an invoice from Wise rclxub.gif
TSKingArthurVI
post Apr 24 2025, 11:29 PM

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QUOTE(poooky @ Apr 24 2025, 08:46 PM)
How to submit einv? Do we just issue and then upload onto portal? Or do we need to purposely subscribe account software?

Seems like details unclear. Only thing that is clear is  gamen die2 want implement einv.
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Sign up on portal and there should be a way to start a new draft of your invoice. Once finalized, they’ll add a QR code to it, I think.
TSKingArthurVI
post Apr 26 2025, 04:26 PM

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QUOTE(tzxsean @ Apr 26 2025, 07:12 AM)
if Wise has a local presence, they are required to issue e-invoice to you

if not, just issue self-billed e-Invoice for foreign entity.
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If issuing self billed e-invoice, would it be from me to Wise to claim the debit amount of transaction fee? Do I actually need to send it to them?
TSKingArthurVI
post Apr 28 2025, 02:14 PM

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QUOTE(purplefellow @ Apr 22 2025, 10:41 AM)
Interested to know as well since I'm in the same shoes as you. But just a heads up, e-invoice phase 3 has been delayed to Jan 1, 2026.
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QUOTE(tzxsean @ Apr 26 2025, 05:45 PM)
you can double check with the IRB e-Invoice helpdesk but I don't think you need to send to them if they are not in scope to implement e-Invoicing.
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LHDN finally replied to my email.

Summary is that we don't need to do anything special.

QUOTE
As mentioned in the Specific Industry FAQ – Financial Services, Section A, Item 16, any foreign exchange gain or loss (whether realised or unrealised) does not require the issuance of an e-Invoice.
Since a foreign payer cannot issue a self-billed e-Invoice, the obligation remains with the Malaysian taxpayer to issue the e-Invoice to the foreign payer.

In your case, you should issue the e-Invoice based on the invoiced amount (in MYR equivalent at the exchange rate on the invoice date), without adjusting for the Wise fee or any exchange loss.
The difference caused by the Wise platform fee is considered a normal business expense or foreign exchange loss and does not require a separate e-Invoice.
TSKingArthurVI
post Apr 28 2025, 04:39 PM

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QUOTE(contagiouseddie @ Apr 28 2025, 03:21 PM)
Wise still okay, small fee only. Mine on PayPal and Stripe, their service fee is much higher.
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No worries... just charge it back to your clients brows.gif
TSKingArthurVI
post Apr 28 2025, 08:48 PM

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QUOTE(tzxsean @ Apr 28 2025, 07:37 PM)
tbh .. conversion fee is not accounting or audit adjustment for foreign exchange differences

based on my experience with the IRB, not all officers are well verse in e-Invoicing despite them being in e-Invoice Helpdesk team.

Keep this email to safeguard yourself for future dispute during audit
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I think should be correct.. based on https://www.hasil.gov.my/media/acil1u20/spe...-unit-trust.pdf, see page 6 (item number 16)

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TSKingArthurVI
post Apr 29 2025, 12:02 PM

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QUOTE(purplefellow @ Apr 29 2025, 10:11 AM)
Thanks, good to know! We need to balance the shortfall (forex loss, fees, etc) from the accounting side then? Feels like a lot of work just to keep track of these tiny fees individually rclxub.gif

Currently what my accountant does is if I invoiced a client for say, USD100 and I only received RM420 in my bank through Wise, he just records RM420 in the bookkeeping.
But with the upcoming e-invoicing, he'll probably need to record it at exchange rate ~RM440 and then do some extra calculation to get the actual received value? Haih, LHDN just take my money... why add so much paperwork...
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Yeah... it feels super tedious

OLD way: Just record money in RM420

NEW way: Record e-Invoice issued — money in RM440 (must match invoiced amount), RM20 money out for forex loss (must match invoiced amount minus what you actually got via Wise)

rclxub.gif sweat.gif
TSKingArthurVI
post Dec 5 2025, 12:22 PM

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QUOTE(EnergyAnalyst @ Dec 5 2025, 10:46 AM)
That is great news, thanks for sharing.
TSKingArthurVI
post Dec 6 2025, 09:29 PM

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QUOTE(EnergyAnalyst @ Dec 6 2025, 07:37 PM)
Great news!!!

QUOTE(xander2k8 @ Dec 6 2025, 07:44 PM)
Don’t be too happy 1st 🤦‍♀️ after election which likely due to next year when BMX comes back to lower it will happen immediately

It is only delayed and not total policy abolishment because it will bound to be happens
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Don’t be so pessimistic la… looking at PM’s statement it’s because of feedback from SMEs, and honestly below 1M is small fries to them, if hanky panky also not worth to catch compared to bigger corps.

 

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