Online data reporting obligation of invoices

Category: VAT

We would like to draw your kind attention to the online data reporting obligation of invoices.

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The reporting obligation currently applies to invoices issued by a domestic taxable person * where:

  • the tax passed on exceeds HUF 100,000 and
  • the customer is a taxable person with a Hungarian tax number,

that is, there is no reporting obligation under the current rules for invoices issued to an individual and to a taxable person with a Community or third country tax number.

* Domestic taxable person (VAT subject) is a person who (which) carries out an economic activity and has a tax number, ie includes companies, foreign enterprises with a tax number, other organizations (eg a foundation with a tax number, association, etc.), self-employed and individuals as well.

The reporting rules will change from 1 July 2020 and 1 January 2021.

From 1 July 2020

  • The value limit of HUF 100,000 will be abolished, so in the period between July 1, 2020 and January 1, 2021, all invoices has to be reported where:
    the buyer is a taxable person with a Hungarian tax number.

With the abolition of the value limit, the taxable person is obliged to provide data reporting if he issues his invoice to another domestic taxable person, even if the invoice does not include VAT passed on (reverse taxation, VAT-free due to the public interest nature of the activity, to , the person is not subject to VAT). In order to fulfill the obligation to data transfer, it is necessary to indicate the tax number of the customer on the invoice issued to each taxable person.

From 1 January 2021

The data reporting obligation shall cover all invoices, including invoices to domestic and foreign individuals and enterprises, invoices issued on intra-Community tax-exempt goods supplies and invoices for export sales, except

  • invoices issued to non-taxable persons established or resident in the Community for telecommunications services, radio and audiovisual media services and electronically supplied services (hereinafter together: distance supplied services - VAT Act 45 / A)

The online data reporting obligation also applies for cancellation and for correction invoices.

Issuing the invoices

From 1 July 2020, the deadline for issuing the invoices will be reduced from 15 days to 8 days, ie invoices containing VAT must be issued no later than 8 days after performance (in the case of an down payment invoice within 8 days after determination of the tax payable).

Completion of the data transfer

The data transfer may be provided

  • by manually entering the data of manual invoices in the NAV Online Invoice system. If the amount of tax transferred on the invoice exceeds HUF 500,000 within 1 calendar day, otherwise the data must be submitted within 4 calendar days after the issue;
  • in case of invoices issued with a suitable invoicing program or online invoicing system, the program sends the data to the tax authority automatically, electronically immediately after the invoice is issued.

In case of non-fulfillment of data transfer, the items of the fine do not change either, in the case of a self-employed tax payer HUF 200,000 per invoice, in the case of all other taxable persons the maximum fine that can be imposed is HUF 500,000 per invoice.

Domestic summary report (sheet M)

In accordance with the data transfer obligation, the value limit of HUF 100,000 will also be abolished in the case of domestic summary report from 1 July 2020, so all incoming invoices must be included in the report on the basis of which the taxable person deducts VAT. VAT-free invoices do not have to be entered on sheet M.

In the domestic summary report the full tax base and the amount of value added tax on the invoice received must be shown, regardless of whether the recipient of the invoice only partially exercises his right to deduct.

We would like to draw the attention of our clients where the bookkeeping is done in its own accounting program, e.g. SAP, MS Dynamics AX to contact the software developer in order to comply with the change in legislation outlined above from July 1st. The program must be able to automatically transfer all incoming invoices to the ÁNYK system.

Gubicza Krisztina

chartered tax expert, managing director