19/02/2026
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Updated e-Invoice FAQ by LHDN for Healthcare Industry: Key Insights and Analysis
As part of Malaysia’s ongoing efforts to enhance tax compliance and improve business processes, the Inland Revenue Board of Malaysia (LHDN) has issued an updated Frequently Asked Questions (FAQ) document for the healthcare sector regarding the implementation of e-Invoice, effective from June 14, 2024. This shift towards digital invoicing is in line with global trends, where governments are leveraging technology to streamline tax systems, reduce errors, and combat tax evasion. In this article, we will review the key points from the FAQ and provide an opinion on the potential implications of this shift for the healthcare sector.
1. Continuation of Current Invoicing Practices
One of the most notable clarifications in the updated FAQ is that healthcare providers, including hospitals, are allowed to maintain their existing invoicing practices for various payer types. Whether it’s self-paying patients, insurance companies, or third-party administrators, the current processes do not require significant modification. However, for minors, the invoice should reflect the details of the parent or guardian, ensuring that the billing remains comprehensive and legally sound.
This flexibility is critical as it prevents disruptions in hospital operations. Given the complexity of invoicing within healthcare, where multiple parties are often involved in payment, this continuity allows healthcare providers to gradually integrate e-Invoice without overhauling their systems entirely.
2. Consolidated Invoices for Non-e-Invoice Requests
The FAQ permits hospitals to issue consolidated e-Invoices for patients who do not require individual invoices. This can be done monthly, provided the e-Invoice is submitted to the Inland Revenue Board of Malaysia (IRBM) within seven days after the month ends.
This provision is particularly useful for self-paying patients who may not need an e-Invoice but still require billing documentation. It reduces administrative burden by allowing the aggregation of smaller transactions into a single report, streamlining the accounting process for hospitals while still complying with IRBM requirements.
3. Consultant Billing Arrangements
For hospitals that engage independent consultants or professionals, the FAQ confirms that the current billing structures can remain in place. In cases of co-provision of services, where both the hospital and the consultant charge the patient separately, each party is required to issue its own e-Invoice. In outsourcing arrangements, where the hospital bills the patient for both services, a single e-Invoice will suffice.
This maintains transparency in the billing process and aligns the e-Invoice system with current professional fee structures, ensuring that independent consultants are appropriately taxed without causing unnecessary disruptions to patient care and billing flows.
4. Locum Doctors and Nurses
For locum doctors and nurses hired temporarily, the FAQ differentiates between contracts for service and contracts of employment. Those under contracts for service are required to issue e-Invoices, while employment contracts are currently exempt. However, these exemptions are subject to periodic review and may change in the future.
This clarification ensures that locum professionals engaged as independent contractors are held to the same tax reporting standards as full-time consultants. For hospitals, this also adds a layer of accountability in managing tax-related obligations when hiring temporary staff.
5. Treatment of Deposits and Detailed Billing
The FAQ outlines that non-refundable deposits require an e-Invoice, while refundable deposits do not. Moreover, hospitals must issue detailed bills to patients, ensuring transparency in all charges. This detailed billing helps patients understand what they are being charged for, while the issuance of e-Invoices for non-refundable deposits ensures that all taxable income is appropriately reported.
The updated e-Invoice FAQ from LHDN marks a significant step in Malaysia’s digital transformation. Follow us on social media and subscribe to our newsletter for more updates.
The updated e-Invoice FAQ from LHDN marks a significant step in Malaysia’s digital transformation. Follow us on social media and subscribe to our newsletter for more updates.
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