Hungary real-time invoice reporting

From 1 July 2018 Hungary has introduced real-time, electronic reporting of domestic B2B sales invoice data. The anti-VAT fraud reporting measure applies to all VAT registered businesses, resident or foreign, on invoices with a VAT element of HUF 100,000 (approximately €320) or more. The new live reporting will replace the existing domestic sales ledger listing, which is filed monthly with the VAT return.

Webinar – Hungary real-time invoice reporting

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Key features of Hungarian real-time invoice reporting

Scope of new requirements

  • Applies to all Hungarian VAT registered businesses, resident and foreign
  • B2B Sales invoices with an invoice element above HUF100,000 (approximately €320) are subject to inclusion
  • Exports, EU dispatches, domestic reverse charge and B2C transactions are excluded from the requirement to report
  • Invoice data to be transmitted is based on the requirements of the Hungarian VAT Act
  • Penalties for late or missed submissions will be up to HUF 500,000 (approximately €1,600) per invoice
  • The existing domestic sales listing will be withdrawn. This is filed monthly with the VAT return. However, the domestic purchase listing will still be required to be submitted.

Submissions

  • Submissions will be to the Hungarian National Tax and Customs Administration (NAV) via the new KOBAK online portal, with sandbox environment now live
  • The process of submissions must be fully automated over the internet from accounting, ERP or billing systems, without manual intervention.
  • Filtered invoice data must be converted into the XML format provided by NAV
  • Submissions should be ‘live’, at the time of the invoice’s creation. This is deemed to happen when the invoice in the invoicing system is finally locked, and can only be changed by issuing a new invoice/credit note
  • Locked invoices may be submitted individually, or through batches of up to 100 invoices per time will be accepted – implying not instant submissions
  • When submitting, firstly an electronic invoice submission token will be issued to the tax payer. This must be then used with the upload of the locked invoice(s) batch. The token is only live for approximately 5 minutes.
  • KOBAK will reply per invoice with one of the following: Accept; Reject and error; Warning
  • An electronic reference number is issued against the invoice. However, this does not need to be printed on the invoice as is just a reference for potential future audits
  • Errors must be resubmitted electronically or manually within three days of the original submission
  • Credit notes and replacement invoices changing the details of reported invoices must also be reported, including changes which increase the original invoice above the HUF 100,000 reporting threshold
  • Invoices produced within manual environments must be submitted electronically within 5 days of their issuance up to HUF 500,000 VAT. Above this limit, then they should be submitted within 1 day

Fines

Failure to provide invoice information in the prescribed format and on time may result in a fine of up to HUF 500,000 (approximately 1,700) per invoice

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