Many of you might think E-Invoice is as simple as what the title suggests: Guest submits and that’s all.
Yes, this might be true for the retail or F&B industry. Unfortunately, this simplicity does not apply to the hotel industry. Let me tell you why.
The hotel industry is characterized by complex transactions and unique scenarios that occur every day. Because of this, the E-Invoice submission process in a hotel setting is incredibly challenging, as it requires dealing with various operational and regulatory complexities.
Let me give you an idea of the daily E-Invoice dilemmas you are going to face:
- A guest books via an OTA (like Agoda, Booking.com, etc.). Should the guest request the E-Invoice from the OTA or directly from the hotel?
- A guest makes a booking 8 months in advance, and a 50% non-refundable deposit is collected today. Can you submit the E-Invoice immediately upon collecting the 50% deposit?
- A guest checks in on 26th May and checks out on 3rd June. When is the submission deadline for the E-Invoice?
- 2 guests stay in one room and request separate E-Invoices. How do you accurately split and submit the E-Invoice in this case?
- The guest dines at a restaurant located within the hotel premises, but the restaurant is outsourced to a separate company. Who is responsible for issuing the E-Invoice—the hotel or the outsourced restaurant?
- A guest checks out on 28th July but returns on 10th August to request their E-Invoice. What is your process and required action in this scenario?
- A guest books a hotel room through a travel agent and then requests the E-Invoice directly from the hotel upon check-out. Is this practice correct from a compliance standpoint?
- The guest initiates a “Self-Bill” transaction to your hotel. What steps does your hotel need to take to process and validate this request?
Hotels operate under a concept of varying point-of-sale and point-of-consumption. Unlike a simple retail transaction where money and goods are exchanged instantly, a hotel transaction can involve:
- Progressive Payments: Deposits, pre-payments, and final settlements.
- Mixed Transactions: The final bill is a mix of room revenue, F&B, laundry, minibar, and sometimes spa/gym services, each potentially subject to different E-Invoice rules.
- Third-Party Intermediaries: OTAs and travel agents are the true client for the room, even if the guest is the one staying.
The scenarios above are just the tip of the iceberg. There are many more complexities that require substantial preparation and investment:
- Integration Challenges: Does your Property Management System (PMS) seamlessly integrate with the Inland Revenue Board (IRB or LHDN)’s E-Invoice platform, or will manual work be required?
- Data Accuracy & Validation: Every E-Invoice requires the buyer’s Tax Identification Number (TIN) or MyKad/Passport number. What happens when a guest refuses to provide this or provides incorrect data?
- Correction and Cancellation: A guest checks out, but later a refund is required due to a billing error. What is the process for submitting a Correction or Cancellation E-Invoice?
There are countless other situations that will arise daily, demonstrating that for the hotel industry, E-Invoice is far from a simple “submit and settle” process. Hotels need robust systems and clear protocols to navigate this complex regulatory change successfully.
