Of the four LHDN items a new Sdn Bhd meets, only one is automatic: LHDN registers the company tax number itself for a company SSM incorporated online. The other three are yours — the CP204 estimate within three months of commencing business, the employer tax file and Form E, which LHDN wants even from a dormant company, and e-Invoice once your phase arrives.
Key takeaways
- LHDN states the “TIN for company (C) is automatically registered” for a company that registered online with SSM — but its page still names MyCoID, which CRS replaced on 14 July 2026. Confirm the number in MyTax.
- The first deadline is not a tax return but the CP204 estimate, due “within 3 months from the date of commencement of the business”. Missing it is prosecutable.
- Hiring does not switch the employer tax file on. LHDN requires even a dormant Sdn Bhd to “register and furnish Form E”.
- e-Invoice is where new companies get caught: a corporate shareholder or holding company turning over RM3 million or more costs you the exemption, whatever you earn.
On this page9
Which LHDN registrations does a new Sdn Bhd actually need?
Four things, with four different triggers: the company tax file comes with incorporation, the CP204 estimate with commencing business, the employer tax file with being a company at all, and e-Invoice with the phase your turnover and shareholding put you in. Three of the four are easy to miss.
| LHDN item | What triggers it | When |
|---|---|---|
| Company tax file and TIN (the “C” number) | Incorporating through SSM | Automatic on online SSM registration; confirm it in MyTax |
| CP204 estimate of tax payable | Commencing business operations | Within 3 months of the date operations begin |
| Employer tax file (the “E” number) | Being a company, dormant or not | No registration deadline published; the first hard date is Form CP22, within 30 days of a hire |
| e-Invoice on the MyInvois system | Turnover, and who your shareholders are | 1 July 2026 or the commencement date, whichever is later, unless you meet the exemption criteria |
Is the company tax file automatic, or do you still have to register it?
Usually it is already done. LHDN's company tax file registration page, last updated 4 August 2026, states that the “TIN for company (C) is automatically registered for newly incorporated companies (local companies or foreign companies) that have registered online with the Companies Commission of Malaysia (SSM) via MyCoID Portal”. Your job is to confirm that number on the MyTax portal, mytax.hasil.gov.my, not to apply for one you already have.
LHDN's page has not caught up with SSM, though: the portal it names is closed. SSM's Practice Directive 1/2017, revised 14 July 2026, states that “Effective from 14 July 2026, all corporate filings, statutory lodgements, incorporation application, notifications and all other submissions to the Registrar shall be made through the Corporate Registry System (CRS)”. So a company incorporated since then used CRS, the system that replaced MyCoID, and should look its C number up rather than assume.
Where a file does still have to be opened, the paper route is gone: since “1 January 2024, application for Tax Identification Number (TIN) registration for Company must be made online through the e-Daftar application” (LHDN, e-Daftar). The duty sits with the company, not the registry: “Registration of company's tax file is the responsibility of the individual who managing and operating the company.”
The documents it asks for sit with your company secretary: the Notice of Registration under Section 15 of the Companies Act 2016, the Certificate of Incorporation under Section 17, and the Section 58 notification of directors, managers and secretaries, lodged at SSM. The LHDN side and the SSM side are not two separate jobs.
What is CP204, and why does it fall due before your first tax return?
CP204 is the company's own estimate of its tax payable for the year, due for a new company “within 3 months from the date of commencement of the business”. The return — Form C, with Form R — is not due until seven months after the financial year end, so CP204 almost always arrives first, often before the first invoice.
The basis is paragraph 107C(4)(a) of the Income Tax Act 1967, in LHDN's tax estimation guidance: where the first basis period is “not less than six (6) months”, the e-CP204 is due “within three (3) months from the date operations begin”. A first-year company estimates on its own projected profits, because the minimum-amount rule in 107C(3) “applies only starting from the second year of assessment”.
- Fix the date operations actually commenced — that date, not the incorporation date, starts the clock.
- File e-CP204 within three months of it.
- Pay instalments from the sixth month of the basis period, under subsection 107C(6).
- File the company's return, Form C with Form R, within 7 months of the financial year end.
Skipping it does not help. LHDN sets the figure itself by “issuing a Notice of Instalment Payment (CP205) under subsection 107C(8)”, and not submitting is prosecutable under paragraph 120(1)(f): “a fine of not less than RM200 and not more than RM20,000, or imprisonment for a period not exceeding 6 months, or both”.
When does the employer tax file become compulsory?
Earlier than hiring. LHDN wants the employer file from the company itself: even one that is dormant or has not commenced business is “required to register and furnish Form E”. Taking on staff starts the calendar that hangs off that file, not the registration — a “business or company which has employees shall register employer tax file”.
That calendar is what catches new employers: Form CP22 for each hire “within 30 days after the commencement of employment”; the monthly tax deduction (MTD/PCB) remitted “on or before the 15th day of the subsequent month”; Form E with C.P.8D “on or before 31 March of the following year”, and Form E “will only be considered complete if C.P.8D is submitted within the specified period”; Form EA to each employee “on or before the last day of February”; records kept for 7 years. EPF and PERKESO are separate regulators — see what to do after incorporating a Sdn Bhd.
Does a brand-new Sdn Bhd have to issue e-Invoices?
It depends on your turnover and, less obviously, on who owns you. The Government “has exempted taxpayers with annual turnover or revenue below RM3 million from the issuance of e-Invoice” — but the exemption has conditions, and a new company with a corporate shareholder can fail them while earning almost nothing.
e-Invoice is phased by turnover in the “Financial Year 2022 Audited Financial Statements”. A company incorporated in 2026 has none, so LHDN's e-Invoice FAQs take the new-company case separately: a business commencing from YA2026 onwards that cannot meet the exemption criteria “is required to implement e-Invoice starting from 1 July 2026 or upon the operation commencement date, whichever later”.
The criteria are where the surprise sits. The exemption does not apply where the company's own non-individual shareholder, holding company, related company or joint venture turns over at least RM3 million. LHDN's worked example is a subsidiary on revenue of RM400,000: “RC Cycling Sdn Bhd does not qualify for the exemption because it is a subsidiary of another company (i.e., JT Motors Sdn Bhd) that is required to implement e-Invoice”. Nor is it permanent: once turnover reaches RM3 million, e-Invoice starts “from 1 January in the second year following the YA” in which it did — separately from whether your Sdn Bhd still needs an auditor.
Does a dormant Sdn Bhd still have to register for Form E?
Yes. LHDN states that companies “which are dormant and/or have not commenced business are required to register and furnish Form E with effect from Year of Assessment 2014”. A company that has never traded, hired or invoiced still has a filing identity at LHDN to maintain.
What can your company secretary do, and where does a tax agent take over?
A company secretary holds the SSM side: incorporation, the statutory registers and resolutions, the registered office, and the Section 58 notification LHDN asks to see. Computing tax, filing CP204 or Form C, and advising on your e-Invoice position are tax-agent work. PT Corporate Services is a corporate secretarial firm, not a tax agent, and we do not give tax advice.
The boundary is practical: the dates driving the LHDN calendar — commencement of business, the appointment of officers, the opening of the company's bank account — sit in the secretarial file.
Frequently asked questions
Does a new Sdn Bhd have to apply for a company tax number?
Usually not. LHDN registers the company TIN automatically for a company that registered online with SSM. Its page still words that as the MyCoID portal, which CRS replaced on 14 July 2026, so confirm the number on MyTax rather than apply. Where a file must be opened, the application goes through e-Daftar.
When is CP204 due for a company that has just started trading?
Within three months of the date operations begin, where the first basis period is at least six months — paragraph 107C(4)(a) of the Income Tax Act 1967. The clock runs from the commencement of business, not incorporation, and the two are often months apart.
Does a Sdn Bhd with no employees need an employer tax file?
Yes. LHDN requires even a dormant company that has not commenced business to “register and furnish Form E”, so hiring is not what switches the employer file on. Employees add the calendar: Form CP22 within 30 days of a hire, the monthly tax deduction (MTD/PCB) by the 15th, C.P.8D with Form E, Form EA for each employee.
Sources
- LHDN (HASiL), Company Tax File Registration — automatic TIN registration via MyCoID, e-Daftar at MyTax, Form E for dormant companies, the CP204 and return deadlines. Last updated 4 August 2026.
- LHDN (HASiL), Tax Estimation — sections 107C(3), (4)(a), (4)(b), (6) and (8) of the Income Tax Act 1967, the CP205 notice, the paragraph 120(1)(f) penalty.
- LHDN (HASiL), e-Daftar — who must register, and the document list including the Section 58 notification.
- LHDN (HASiL), Employer's Responsibility — MTD/PCB, Form E with C.P.8D, Form EA, Form CP22, the seven-year record rule.
- LHDN (HASiL), e-Invoice General FAQs — the phased thresholds, the RM3 million exemption and its Section 1.6.10 criteria, businesses commencing from YA2026.
- SSM, Practice Directive No. 1/2017 (Revised 14 July 2026) — incorporation applications and statutory lodgements through CRS from 14 July 2026.