Amongst others the name of the invoicing program, version, developer’s details must be reported. The invoicing software used must comply with strict requirements such as sequential numbering of the invoices, etc. Failure to use the appropriate software and failure to report it results in administrative penalty of up to EUR 1 700. Examples of inappropriate invoicing software include the use of Microsoft Excel or Word.
From 2016 the invoicing software must also be capable of collecting data in pre-defined format to the Hungarian Tax Authority in case of the tax audit. The Hungarian Tax Authority has issued a detailed guidance on how the standard accounting file (SAF) should look like, more specifically which fields should be reported and how.
What it means potentially to your business
The Hungarian Tax Authority is very peculiar in respect of the structure of the fields of the SAF. This may cause issues if your software is not wired in the same way. For example, under the new specification, the number of the house block in your or your customer’s address must be in a different field that the street name, city and postal code, names of all fields are predefined such as #house #number, #street, #city, #postal code. If previously you have entered the number of the house block, street name, city or postal code in one single field codenamed #address or #other information, then your invoicing software will not be fit from 2016. Similar specifications exist in respect of taxable base, VAT amount and the nature of the invoice (normal invoice, credit note, etc).
The new invoicing requirement raises many legal questions as well, for example to what extend can an EU member state introduce new requirements with respect of the invoicing software without expanding of the invoice content as specified in Article 226 of the EU VAT Directive.
Next steps
You may need to check whether your invoicing software is in line with the guidance issued by the Hungarian Tax Authority. If you are using an external software, you may need to contact the software developer and seek confirmation that the software is compliant. If you have outsourced your invoicing function or if your customer practices self-billing in your name, you may need to contact the person that issues invoices on your behalf to seek such confirmation.
Possible consequences of non-compliance
If the invoicing software you use is not in line with the new requirements or if you fail to report the invoicing software to the Hungarian Tax Authority, you may face an administrative penalty of up to EUR 1 700. We believe that the probability of such penalty remains low during the introductory phase of the new regulation. However, if the administrative penalty is imposed frequently, the Hungarian Tax Authority may take even tougher stand during the tax refund requests and tax audits.
How can RSM Hungary help
We can help you to better understand your obligations in Hungary and the possible consequences of non-compliance with the invoicing software regulation, so that you can make a well-informed business decision on how to develop your invoicing software. If you have outsourced your invoicing function to us, we hereby confirm that our software is in line with the new regulation and is reported to the Hungarian Tax Authority.
