New paragraph 1.6.10 of e-Invoice Guideline Version 4.8 (30 August 2026) says the RM3 million exemption does NOT apply if your business has a non-individual (corporate) shareholder with annual turnover or revenue of at least RM3 million, if you are a subsidiary of a holding company at or above that level, or if you have a related company or joint venture at or above that level. So a business turning over RM2 million should not automatically conclude it is exempt: if it sits inside a bigger group, or a company owns a stake in it, the mandate can still apply. "Related company" is interpreted by reference to section 2 of the Promotion of Investments Act 1986. The conditions appear intended to stop larger groups from routing activity through small subsidiaries to claim treatment designed for genuinely small, independent businesses.
Regulation · 🇲🇾 Malaysia
The RM3 million exemption is not a simple size test — group and ownership rules can still catch you
In forcescopeEffective 2026-08-30
1
Write down your own annual turnover or revenue and keep the workings you used to calculate it.
2
List every corporate shareholder, holding company, related company and joint venture connected to your business, with each one's turnover.
3
If any of them reaches RM3 million, assume you are still in scope and keep issuing e-invoices.
4
Keep your working papers on file in case LHDN asks you to justify the exemption.
Sources: VATupdate — Malaysia raises e-Invoice exemption threshold to MYR 3 million (31 Aug 2026) · LHDN/HASiL — official e-Invoice guidelines page
✓ Verified against sources on 2026-09-01 · updated when the regulation changes
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