To which invoices does online invoice data reporting apply in 2021?
From 2021, data will not only have to be reported on invoices issued to VAT-able partners registered in Hungary but on all issued invoices to which the invoicing rules of the VAT Act apply. This means the online invoice data reporting obligation will apply to invoices issued to Community and non-EU partners as well as private persons. This also includes webshops, which will have to report their invoice data to the tax authority through the Online Invoice system until 1 July 2021, the launch of the OSS system.
This also means that a large number of new entrants will have to join the Online Invoice system, who were so far not obliged to report data as they did not issue domestic B2B, i.e. business-to-business invoices.
How do you have to fulfil your online invoice data reporting obligation to HU TA?
The online invoice data reporting obligation means that the data content of the invoice (or document equivalent to an invoice) must be reported immediately upon issuing in XML format and in the structure specified by the tax authority electronically without human intervention. If the taxable person still uses a manual block of invoices, he may report data manually through the Online Invoice interface.
Which data have to be reported to HU TA?
The process and the content requirements of invoice data reporting are included in the developer documentation and the data reporting schemas published by HU TA. Online invoice data reporting applies to at least the compulsory data of invoices prescribed by the VAT Act and to the data specified as compulsory data in the schema. The schema currently applicable is the 3.0 XSD schema. (You can read more on the XSD schema changes in December here.) You should also examine the option of reporting the total data content as, in this case, you can use data reporting for other opportunities and other obligations also.
What do I have to do to start online invoice data reporting now?
1)First you have to register in the HU TA Online Invoice system
The first step of the fulfilment of the online data reporting obligation is registration, which can be performed by the company's representative or authorized person. The registration process is completed by the creation of a technical user (a virtual user for successful data reporting through the computer-to-computer interface) and the relating keys.
2)You should check whether your invoicing program is able to fulfil the online invoice data reporting obligation?
If your invoicing program takes care of online invoice data reporting, you have to examine whether the settings in the invoicing program are appropriate, whether all invoices to be reported were selected and whether the XML includes all data that must also be shown on the invoice.
If your invoicing program/ERP does not send data to the HU TA Online Invoice system, you have to make sure that it does. You may fulfil your online data reporting obligation using an external data reporting module. In this case, the technical user created during registration must also be recorded in the data reporting module to ensure successful connection to the HU TA server.
3)Testing of online invoice data reporting
When your invoicing program is ready for online data reporting, you should test your settings. A few tests should be performed for each type of outgoing invoices (using only test invoices, of course).
Online data reporting
with an external module
What should you pay attention to if you need an external data reporting module?
You should, by all means, chose a solution that ensures the monitoring of warning and error message responses from the tax authority and gives notice to the user in the case of an error. If HU TA rejects your data report and does not accept the XML with reference to the causes detailed in the developer documentation, you must correct your online invoice data reporting.
All users must be aware that failure to comply with the data reporting obligation comes at a risk of a high penalty: the cap on the fine is 500,000 forints per invoice.
We have to note that the January change of online invoice data reporting is also preparation for the new 3.0 version as, from the beginning of the year, the obligation has to be fulfilled according to the 3.0 version. However, the tax authority granted a grace period until 31 March 2021 as data reporting according to the previous 2.0 schema version will also be accepted by HU TA until this date.
The reporting obligation also comes with services provided by the authority such as, for example, the option of checking domestic tax numbers and supplier invoices and the supporting of electronic invoicing within the data reporting system.
If you use your own solution or an invoicing program developed abroad, which does not include an option for the fulfilment of the Hungarian statutory data reporting obligation, development may be a substantial challenge.
For this reason, you should involve experts in the process that are able to support your company both on the tax and on the technical side. External help may be used in the checking of the quality of the generated XML files but also at a number of other points and data sending can also be outsourced built on an external application which may also be cloud-based granting access both to remote employees of a foreign parent company and domestic employees (in any time zone).
Registration for the starting of online invoice data reporting
The tax authority publishes news on data reporting updates, developer documentation and legislation on the Online Invoice website. After registration in the Online Invoice system, you can check the status of your data reports, the invoices reported by your company or your partners as well as the manual data reports mentioned above.
