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Online invoice data reporting – handling of special items

Real time invoice data reporting sets out explicit rules on the tasks related to invoices compliant with basic criteria. The legal regulation also provides guidelines on what to do in cases when the original invoice is not included in the set of data required to be reported, but due to its “afterlife”, it nevertheless generates a reporting obligation.

The question promptly arises for practitioners, but what to do with the data of amending or reverse invoices. The simplest solution for the company to avoid the problem is to report the data of all invoices issued between taxable persons to the Hungarian Tax Authority (HU TA),regardless of the value limit. The regulation does not exclude this, and later on, if the VAT threshold value is decreased, there will be no need to modify settings and systems. 

How about amending invoices? It depends …

In the event that the company only intends to forward data on items reaching or exceeding the value limit – in compliance with the requirement –, attention should also be paid to subsequent changes affecting transactions. The regulation exactly specifies the things to do in case of amending and reverse invoices as well, stipulating that if the original invoice has been reported, the data will also be required to be reported on any related amending invoice(s). 

If the value of the original invoice has not reached the threshold value for reporting, but the corrective invoice has increased the aggregate VAT content to exceed HUF 100,000, then the corrective invoice must already be reported, together with all subsequent corrections. Unfortunately, the data content of the original invoice must be monitored and stored in such a case as well, in order to know which are the amending invoices that are required to be reported and which are not. This problem area can be avoided if the company decides to report all its invoices issued to domestic taxable persons, regardless of the limit amount. 

Hungarian Tax Authority may also provide new services in addition to invoice data reporting 

As a “by-product” of real-time invoice data reporting, the tax authority may also provide extra services to reporting companies in the future. Separately from data reporting, the validity and correctness of Hungarian tax numbers can be queried, and data senders can also query partners’ data reportings reported in respect of their company. 

This latter may even be very useful in the future since if the company’s partners do not filter the data on the invoices submitted and they also report invoices with a VAT content below HUF 100,000, then – by querying their data reporting – the data content of invoices can be imported into accounting software, reducing manual work. In addition to the manual processing of purchase invoices, the enterprise can integrate a supplementary control point in its processes: comparison of the data of manually processed invoices with the data available in the system of HU TA. However, the manual processing of invoices should not be buried until it is made sure with absolute certainty that the supplier business partner has met their date reporting obligation absolutely correctly. 

It is also intended to develop an online invoicing software on part of the tax authority which can be used by anyone free of charge but is subject to registration. 

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