According to the Act CXXVII of 2007 on Value Added Tax in force since 1st July 2018 the taxpayer is obliged to report data on invoices which were issued with VAT exceeding HUF 100.000.

What has this meant in practice so far?

In case of invoicing by using an invoicing software, the invoice data must be provided to the Hungarian Tax Authority immediately without human intervention.

In case of printed invoices for example using invoice pad – so in cace of manual invoicing – data must be reported to an online (web) platform. Data provision shall be performed within 5 calendar days, exception to this if the VAT amounts to or exceeds HUF 500,000. Such invoices shall be registered on the online platform the day following day of the issue date.

Expected changes from 1st July 2020

AS of 1st July version 2.0 of the XSD data structure must be used. From this day on version 1.1 is not suitable for data provision. Data provision obligation can only be performed based on the requirements of version 2.0

The range of invoices subject to online data providing is expanding. All invoices on transactions in Hungary between taxpayer registered in Hungary issued after 1st January 2020, (excluding intra-Community supplies of goods exempt from tax) must be reported, regardless of the amount of VAT.

The online data providing obligation will also affect taxpayers who issue invoices on the supply of goods and services which are subject to the domestic reverse charge mechanism in Hungary and/or are VAT-exempt.

From 1st July an invoice must also be issued for certain transactions for which it has been sufficient to prepare an accounting document so far. These invoices are also subject to the online reporting obligation.

The changes in the online data providing will cause additional administrative burden to the invoice recepient, because from 1st July 2020 the invoice recipient will be required to provide data in respect of all incomming invoices of which VAT has been deducted.

The data provision must be fulfilled by the summary document attached to the VAT return. In case of modification or cancellation, the related modification invoice of the invoices indicated in the summary document must also be declared, regardless of the value limit.

Fom this date, the tax number will become a mandatory content element of the invoice if the product or service is sold to a taxable person registered in Hungary.

According to the transitional provisions, the date of the invoice is relevant for the exercise of the right to deduct. If the invoice was issued before 1st July 2020, but with a completion date after 30 June 2020, the taxable person may exercise his right to deduct tax even if his tax number is not included in the invoice (provided that the amount of VAT doesn’t reach HUF 100,000).

However, if the invoice is issued after 1st July 2020, it can only be eligible for a tax deduction if it includes the customer’s tax number.

Manual entry of invoice data in the NAV online invoice system will casue significant additional administrative burden for users of invoice pad. The deadline for reporting data will also be shortened. Instead of the current 5 calendar days, the data of the invoice issued after 01.07.2020 must be provided within 4 calendar days after the invoice is issued, in case of invoices with VAT amounting to HUF 500,000 data must be provided at the latest on the calendar day following the issue date.

Further tightening is that from 1st July 2020, the deadline for issuing invoices will be reduced from 15 days to 8 days. In the case of payment by cash or credit card, it is unchanged that the invoice must be issued immediately.

Expected changes from 1st January 2021

From 1st January 2021, data must be provided for all invoices that had to be issued according to Hungarian rules (i.e. also for invoices where the buyer is a natural person), except for transactions with non-taxable persons in another EU Member State, after which the taxpayer’s tax liabilitiy will be fulfilld by using the One-Stop Shop (MOSS) system.

What tasks do the new provisions entail?

Those who are newly covered by the data provision obligation should consider whether their invoicing program is suitable for fulfilling the online data provision obligation, and should ensure registration in the online invoice system (http://onlineszamla.nav.gov.hu/). of the Hungarian Tax Authority.

Those who have been required to provide data so far need to make sure that their invoicing system meets the requirements of version 2.0.

We recommend to those, who are using an own invoicing software to contact the developers of the the software.

Those who have used an invoice pad so far are advised to switch to an invoicing software , as manually recording of the data of all invoices will be a significant administrative burden.

What sanctions can be expected for those, who fail to comply with data provision obligations?

Those, who fail to comply with their data provision obligations the amount penalty can be as high as HUF 500 000 per invoice.

This document can be downloaded in PDF format by clicking on this link: Changes in Online Invoicing methods