We specify below exactly what changes took place, why the amendment of the schema was necessary after hardly seven months since the launch of the online invoice decree and what tasks the transfer to the new scheme version 1.1 represent for developers and companies.
Very tight deadline for the RTIR modifications
From May 2019, the method of generating invoice XML-s and that of submitting these will change at the same time. The changes themselves are not large, however, new developments have to be implemented on invoicing programs and invoice reporting modules, which may place a burden of varying size and complexity on companies depending on their situation and abilities.
The companies that have already been using invoicing programs with reliable technical and support background continuously and automatically adapted to and in full compliance with Hungarian legal regulations, will probably see through the next few months without any concerns. However, the taxpayers who already had to devote substantial efforts to achieve online invoice data reporting based on the XML 1.0 schema, will have to face new challenges. Until the end of April, changes in both data XML and data communication XML will have to be adopted. For them, the short deadline of three months may seem frightening, to which it is only small relief that HU TA already made testing using 1.1 XML documents in its systems available at the time of the announcement of the changes.
What changes will be in the content of invoice data reporting?
HU TA specified the improvement of data quality as the purpose of the changes. To this end, they expect more detailed data reporting from invoicing programs at several points. This means the introduction of new data elements on the one hand and the making of certain items (previously optional) compulsory in the XML documents on the other hand. Without knowledge of the internal systems of HU TA, it is difficult to judge from the outside precisely why the provision of derivative information, i.e. information that can be generated from already available data is necessary and why the authority finds that data beyond the ones prescribed by the VAT Act has to be included in the invoice reports.
The changes basically concern four points of which not only those should be aware who is working on the generation of XML files but anyone who is concerned by data of appropriate quantity and quality being available for the generation of the XML documents in the invoicing systems.
1.Applied exchange rate
The most interesting part of the new XML is probably the compulsory exchange rate requirement. This previously optional element will have to be included in every data reporting from May, even if the invoice is issued in HUF. A fixed value of 1 will have to be stated for HUF invoices as the exchange rate and the exchange rate applicable at the closing of the account in all other cases. This will definitely challenge developers if this data could so far only be included in the remarks section of the invoice, i.e. if the program does not provide a separate field for recording the exchange rate applied. Special attention will have to be paid in the case of foreign exchange rectifying invoices as the exchange rate also became a compulsory element in the data reporting relating to these invoices.
In the invoicing systems, we are familiar with, general practice was so far to leave this optional field empty. This will have to change by all means to comply with XSD 1.1.
2. Compulsory aggregation by VAT rates
The optional application of the aggregation by VAT rates will also become a compulsory data element. From May, the tax authority will only accept invoice XML documents in which this element is also provided. The integration of this data seems to be an entirely technical task. Based on our experience so far, the invoicing systems we worked with basically have already included this (typically compulsory) element common on invoice images in the XML files.
However, we would like to draw attention to the fact that in the case of rectifying invoices for which the change does not concern the invoice lines, the aggregation by VAT rates will have to be included nonetheless! In the cases where this data was already a part of the XML previously, this does not require any amendment during the switch to version 1.1.
3.Quantity units stated on the invoice
The tax authority expects an amendment of invoice reports at two points in this regard.
- On the one hand, it will have to be declared for each item whether the quantity and the unit price stated for the item in question can be expressed with a natural unit or not. This will require taxpayers to include a new element. If the value for this new element (specifically: lineExpressionIndicator) is "true", further data will have to be provided in addition to the name of the product or service.
- On the other hand, HU TA published a list for the items that can be expressed in natural units including the quantity units acceptable for the tax authority. As of the end of January, these include: Piece, Kilogram, Ton, Kilowatt hour, Day, Hour, Minute, Month, Litre, Kilometre, Cubic meter, Meter, Running meter, Carton, Box. If the quantity unit shown on the invoice cannot be included in any of these categories, a unique unit can also be recorded.
4.Closed time gate
From May 2019, no date and time before 01/01/2010 may be included in the fields containing date and time type values.
This is important, above all, in the case of data relating to the start of performance or settlement. if the invoicing program fills any missing date (or time) with a default value, it must, by all means, be made sure that this is not a default date before 2010 as the inclusion of such data will block the acceptance of the data reporting.
New error codes were introduced
Partly as a result of the XSD amendment and partly in reaction to previous experiences, both technical and blocking errors and warnings were extended. In addition, the tax authority also tries to decrease the number of warning messages sent out by integrating a less strict rounding algorithm.
What else can be expected in relation to online invoice reporting?
Two further change steps were indicated for 2019 on the website of the Online Invoice Data Reporting System. According to the communication of the tax authority, the XML schema will go through the developments marked as versions 1.2 and 1.3 until the end of 2019 on which, however, no further details have been published so far.
Start preparation for changed invoice data reporting in time!
An updated version of the XML validator is already available on our website with the help of which you can check compliance of the XML data files derived from your invoicing system with the latest 1.1 XSD schema.
With the appropriate XML documents, new type data reports can already be submitted to HU TA today. For this purpose, everything for the implementation of the changes is available on the tax authority's website. Our expert colleagues can provide support in the form of XML consulting so that the developers of your invoicing system can prepare your system for the change as quickly and as efficiently as possible.