As we have former informed you, online data service to the tax authority (NAV) is obligatory from the 1st of July 2018
- about invoices and other documents treated as invoices issued by the invoicing program
- the VAT content of which reaches or exceeds 100,000 HUF and
- the customer is a taxpayer registered inside the country
It is important that the online data service must not only be done about invoices with the above-mentioned features, but also the modification, invalidation of them.
Detailed rules of online data service are published just in form of draft at the time of our previous Information letter, and now as well.
Latest information in connection with details of online data service was published on the site of the Hungarian Government in the second part of January 2018.
(Now this site is available only in Hungarian)
Following documents can be found on the right side of the above mentioned link:
- Actual draft version of the decree of the Hungarian Ministry of National Economy
- Online Invoice System of the National Tax and Customs Administration – Data disclosure REST API interface description and developer’s documentation.
- IT description
The online test system, which we have referred in our Information letter from August 2017 (https://onlineszamla.nav.gov.hu/KobakReg/faces/index.xhtml) is available in a totally renewed form since the 29th of January 2018 on the following link:
(This site is available in Hungarian, in English and in German as well.)
Information on the registration procedure in the Online Invoice System raises some questions, we have already asked a statement from the Hungarian Tax Authority about them. As soon as we receive answers, we will inform you.
Regarding to undermentioned legal consequences we recommend you – despite of that the related decree is available just in form of draft and questions related to registration – to start the preparation for the online data service as soon as possible, to contact the developer of the invoicing program used by you, forward them availability of above mentioned sites and IT documents.
From above mentioned information it can be stated that the online connection of invoicing programs is primarily and basically an IT issue.
But, if online data service doesn’t function or the functioning isn’t adequate, the Hungarian Tax Authority will hold responsible and fine the user of invoicing program.
According to the currently available information the sum of the fine can reach 500.000 HUF per invoice.
Moreover, if online data service doesn’t function or the functioning isn’t adequate, customer’s (recipient of invoices) right for deduction of VAT will be in danger.
One of the conditions of right for deduction of VAT is the invoice, which is issued complying with related rules.
If the invoicing program doesn’t fulfil online data service or the online data service isn’t adequate; in this case the invoicing with such program doesn’t comply with related rules.
Hungarian Tax Authority can refuse right for deduction of VAT related to invoices, which have been issued with such invoicing programs.
Furthermore we are considering important – regarding to above mentioned fine and other risks – that you clarify the details of liability for damages related to not or not adequate functioning of online data service, in the agreement which you bind in connection with this theme with the developer of your invoicing program.
Due to the general nature of our Information letter, this can’t be considered as a decision -justifying consultation. With regard to this, please be as so kind to contact our colleagues with your specific questions in connection with this Information letter.
Budapest, 20 February 2018
Dr. Anikó Emese Boros, Tax advisor
Krisztina Gubicza, Certified tax expert