Earlier this year we reported about the soon-to-be Hungarian invoice data reporting export requirement, and more importantly, about unanswered questions at the time. This summer, a draft regulation (modifying Decree 23/2014. (VI. 30.) NGM) was published, shedding some light on many of those questions:
When is the obligation entering into force?
As expected, the previous deadline of 01 July 2017has been postponed. In the draft regulation, the date for entry into force of the obligation has been set for 01 July 2018, one year after the first deadline.
Is Clearance-style real-time reporting being introduced?
Well no, not really. As of yet, no EU Member State has truly introduced Clearance country style mechanisms, whereby taxpayers must send their invoices to be “cleared” by the local tax authority for them to become fiscally valid. But a couple of countries are doing what they can to attain the same goal (i.e. enhance control and access by the authorities to transaction information by implementing more frequent and invoice-focused e-reporting requirements).
The Hungarian draft proposal sets out an obligation for taxpayers to report invoice data to the tax authority after the invoice has already been issued, but no later than 24 hours after issuance. That is a much smaller window than in Spain, which as of 01 January 2018 will require the invoice data to be reported within four days after issuance, or Portugal, where such data must be reported the following month.
How can taxpayers and solution vendors prepare?
For the time being, the tax authority has not yet made testing the electronic communication protocols possible. A detailed (100+ pages) technical specification was published together with the draft regulation, so right now the only thing taxpayers and solution vendors can do is to read up, and monitor developments so that testing can happen as soon as it’s made available by the tax authority.
The Sovos team is continuously monitoring and analyzing global e-invoicing and e-reporting trends, and we’ll be following the Hungarian developments leading up to the entry into force in with much interest.
Have you been affected by this evolving situation in Hungary?
- Has your ERP vendor communicated with you about the upcoming changes?
- Are you discussing any add-ons for Hungarian, Spanish or related dynamic invoice reporting with third-party vendors?
- If you’re an international enterprise with a Hungarian subsidiary, how does your local team assess the impact on your global IT and processes?
- Have you had any interaction with the Hungarian tax authority about these matters?