Pursuant to the VAT Act, taxpayers are obliged to ensure the issuance of an invoice at the latest until performance, or until the determination of the tax payable in the case of advance payment, and not later than within a reasonable time thereafter. The reasonable time available to issue an invoice is determined by the regulation depending on the type of transaction. The obligation to issue an invoice shall be fulfilled from 1 July 2020 as follows:
- In the case of tax-exempt supply of goods within the Community or a supply of services subject to international reverse taxation, no later than within the 15th day of the month following the month of performance.
- In cases other than the supply of goods and services not covered by the previous case and performed by means of automatic equipment without operating personnel, where the consideration, including the advance payment, is reimbursed in cash or by a cash substitute payment instrument, immediately.
- In other, general cases, when the invoice contains or should contain the VAT payable, the invoice must be issued within 8 days.
We have previously written in detail regarding the dates on the invoice, the date of issue of the invoice, the date of performance, the payment deadline and their VAT implications. Each date has (or may have) an important role in the invoice, depending on the content of the transaction, e.g., it is important to know whether the transaction in question is HUF/foreign currency-based, a periodic settlement or an instalment payment. The date of performance in the invoice is data that is included in the XML data of the NAV (Hungarian Tax Authority) Online Invoice data service as mandatory data, therefore it is automatically included in the data stored at NAV (Hungarian Tax Authority).
In connection with the shortening of the invoice issuing deadline after performance, several tasks and processes need to be considered, not only the reduction of the number of calendar days for the issuance of the invoice.
These are worth paying attention to, for example, if the invoice is not issued immediately and automatically:
- The deadlines for issuing invoices must be in accordance with the deadlines and performance stipulated in the contract and by law
- Is the time for external and/or internal data supply required for invoicing appropriate?
- Financial performance, cash flow planning
- What could be the main obstacles for the issuance of an invoice in time?
- Are we aware of the penalties associated with late invoicing?
- Are reverse charge transactions handled correctly?
- What to do with periodic settlement transactions?