Hungarian Real-Time Invoice Reporting As From July 2018

Online invoice reporting in Hungary mandatory in July 2018

The new obligation will require that any taxpayer registered for VAT purposes in Hungary, issuing an invoice with a VAT amount greater than or equal to report the invoice data automatically, electronically, immediately and without human intervention to the Hungarian tax authority. Not complying with this obligation will carry a fixed penalty of up to HUF 500,00 (EUR 1,700 approx.) per invoice.

At Marosa we offer a software solution that will submit your XML document with the relevant token received from the Hungarian tax authorities. You will be able to correct and amend any error message in a dedicated web-based interface. Please contact us to receive more information about our software.

Hungary is the second country in Europe requiring real-time reporting of tax data, following Spain which was the first one introducing a system for real-time VAT ledgers reporting called ‘Suministro Inmediato de Información - SII’. Several jurisdictions like Poland, Portugal or the Czech Republic have introduced the SAF-T requirement on a periodic basis, but none of them has requested real-time information yet.

Hungarian real-time invoice reporting - what is it about?

The so-called ‘online számla’ consists of the obligation to report the invoices issued electronically and immediately (at the moment of issuance) if the VAT charged is at least of HUF 100,000. This new obligation will require companies to adapt their invoicing and ERP systems in order to produce the XML file that must be transmitted to the Hungarian tax authorities’ website without human intervention.

However, the taxpayer may also decide to disregard the VAT threshold and provide data for all his domestic invoices issued, even though the invoice contains or not any VAT due and the corresponding VAT amount. Hungarian tax authorities also accept voluntarily invoice data provided.

Who is obliged to report this information?

Hungarian real-time invoice reporting is mandatory for (i) all taxpayers registered for VAT purposes in Hungary, regardless whether they are established or not in Hungary, who issue an invoice with a VAT amount of HUF 100,000 or more; (ii) those distance sellers who carry out B2B supplies (online sales business to business performed to Hungarian taxpayers) and charge VAT for HUF 100,000 or more.

Therefore, a taxable person is NOT required to report any information in the following scenarios:

• Invoices issued (sales) with a VAT amount below HUF 100,000.
• Invoices received (purchases).
• Intra-Community transactions: acquisitions and supply of goods and services within the territory of a Member State.
• Imports and exports.
• Domestic sales under the reverse charge mechanism.
• Distance sales under the B2C rule (supplies to individuals).

What is the exact content required?

The content of the XML required by the tax authorities for the Hungarian real-time invoice reporting is, at least, the mandatory invoice data as stipulated in the Hungarian VAT Act. This would include at least the following data:

• The date of issue;
• A sequential number, which uniquely identifies the invoice;
• Supplier´s name, address and VAT number
• Customer´s name, address and VAT number
• The description and quantity of the goods supplied as well as the description, extent and nature of the services supplied if it can be expressed in some unit of measurement;
• The date of the chargeable event and the date of advance payments, if they differ from the date of issue of the invoice;
• The taxable amount, the unit price of goods and services not subject to VAT and any discounts or refund, if they are not included in the unit price;
• The VAT rate applied;
• The VAT amount payable;
• In case you are reporting supplies of goods exempt or zero-rated, the reference to the applicable provision of law, or any other reference indicating that the supply of goods is (i) exempt or (ii) subject to the reverse charge mechanism, if applicable;
• Identify the characteristics pursuant to the Hungarian VAT Act for on the supply of a new means of transport;
• Indicate that the particular provisions have been applied in connection to the activities of tour operators pursuant to the Hungarian VAT Act;
• Indicate that the particular provisions have been applied in connection with the supply of second-hand goods, works of art, collectors’ items and antiques;
• Legal representative´s name, address and VAT number, he is liable to pay VAT.

Please send us an email if you would like to receive the official XML format required by the tax authorities.

Technical requirements? Our solution

You will need to send your invoice data in XML via APIrest to the Hungarian tax authorities. This communication will send back a token that will accept the data and the submission will be confirmed.  The requirement for a token transmission will oblige most foreign companies with an ERP abroad to use a bridge software between their ERP and the tax authorities.

Since 2014 a taxable person registered for VAT purposes in Hungary who issues invoices is required to use an invoicing software which strictly complies with the following requirements, among others:

• Use of continuous serial numbers without any interruption or repetition.
• Use of separate serial numbers ranges for invoices issued to non-Hungarian VAT numbers.
• Use of separate serial numbers ranges for receipts.
• Invoicing software registration in the Hungarian tax authorities (name of the software, tax number of the developer, etc.).

Together with our local delegate, Marosa has developed a solution for the transmission and submission of your XML files. This solution has been fully tested and is now operational.

Please contact us if you would like to receive a demo of our solution for the Hungarian real-time invoice reporting.

What are the next steps?

If you have not yet started working on the Hungarian real-time invoice reporting, you must take the following steps as soon as possible to ensure that you are compliant with the new obligation:

• Evaluate system requirements and confirm that all data required is available in your ERP system.
• Extract of required data from your ERP system in the XML format required by the tax authorities. This step can take several weeks so it is the most urgent action.
• Registration of your business as an online user for real-time reporting
• Set-up of APIrest for data transmission.
• Testing of your XML data checked.

Given the urgency, we suggest starting the process within the first two weeks of March 2018 at the latest.

Please contact us so we can send you an invitation for a conference call to create an Action plan and ensure that you are compliant by 1 July 2018.

What are the penalties?

Failure to report data according to any of requirements described above (electronically, automatically, immediately and with no human transaction) will trigger a default penalty of up to HUF 500,000 (EUR 1,700 approx.) per invoice. Additional penalties would apply for non-compliance with the invoicing software requirements.

Late, incomplete, erroneous or false data reporting will trigger a default penalty for each invoice affected by the failure of up to HUF 500,000 (HUF 200,000 for private individual taxpayers).

More information about the Hungarian real-time invoice reporting can be found on the website of the tax authorities.