[UPDATE – June 2017]
The likely decision to postpone the implementation of changes in VAT reporting has now finally been announced. Hungary has now postponed the entry into force of this requirement by one year until July 2018 for two reasons:
- To actually get the technical specification published well in advance
- To give taxpayers and service providers some time to implement and test their solutions
Original post
Last year the Hungarian government announced changes in regards to VAT reporting: as of 1 July 2017 it will be mandatory for taxpayers to electronically report data in real-time regarding supplies of domestic B2B sales for which the VAT reaches or exceeds HUF 100,000 (corresponding to roughly 320 EUR). When considering developments previously reported in this forum in other countries (Italy, Poland, Spain), we’re spotting an EU-trend.
This reporting requirement builds upon the existing ‘data export functionality’, which has been mandatory for invoicing systems in Hungary since 2016, but takes it one step further by requiring the data to be reported in real-time to the tax authority. Similar to the data export functionality, the real-time reporting is expected to be handled by the ‘invoicing system’, which is the system that should also perform the sequential numbering – likely the service provider’s system in many outsourced scenarios.
The implementing legislation with technical specifications around this requirement was supposed to have been introduced already but has been delayed, which leaves many fundamental questions unanswered and not much time for taxpayers to prepare before the entry into force. One of the most relevant questions concerns the definition of ‘real-time reporting’; have the Hungarians glanced at Clearance countries and truly require the data to be reported in real time at the time of issuance? Or does real time in this context instead mean reporting the VAT data after the issuance but with a very short deadline?
Without further clarifications from the authorities, all discussions on the topic remain speculative, but there’s good reason to believe that the entry into force of the reporting requirement will be postponed – or at least ought to be.
