Another milestone in real-time data feed: interface version 3.0 is coming
According to the current plans, from 0:00 on 1 January 2021, the Hungarian Tax Authority (HTA) will introduce the latest, at the same time final, 3.0 invoicing reporting interface in real-time data provision.
The HTA will provide an additional quarterly grace period for the transition after its introduction, meaning that from now until 31 March 2021, invoicing softwares can be tested without penalty to meet the new requirements.
As a result of the changeover, the current invoice reporting with version 2.0 will be considered as an unsuccessful data submission as of 1 April 2021, which may result in a fine of (up to) HUF 500,000 (approx. EUR 1,400) per invoice. The development documentation and schemas of the new 3.0 interface (called in Hungarian “NAV 3.0”) have been available since 7 September 2020 – also in English – on the official website of the Online Invoice System.
The introduction of the new interface is justified by the fact that, following the changes effective from 1 July 2020, invoices issued to non-taxable persons (e.g. natural persons) as well as Intra Community and export tax-free supplies of goods will be required to be reported from 1 January 2021. As the result of the changes to be introduced in two stages, the entire invoicing system will become transparent to the HTA, which will reduce the risk of tax evasion and VAT fraud to a minimum, and as a result, the legislator expects significant additional budget revenue.
There is a transitional provision linked to both the starting date of 1 July 2020 and the starting date of 1 January 2021, according to which the date of issuance of a given invoice (not the date of performance!) determines whether the “old” or “new” rules shall be applied, i.e. whether or not the account details will have to be provided.
As a result of continuous developments, the Hungarian Tax Authority may be able to prepare a draft VAT return for all taxpayers registered in Hungary from 2021, as it has done since 2017 concerning the personal income tax returns of natural persons.
We would like to draw the attention of companies that do not issue their Hungarian invoices with a Hungarian invoicing software (e.g. they use a program developed within the company group or developed by the parent company) to start the transition to NAV 3.0 immediately, if they have not already done so, because in our experience – depending on the complexity of the given invoicing software – the IT transition can take up to several months. Domestic invoicing softwares must be amended by the service providers developing them, so taxpayers using them do not have an IT task in connection with the transition, of course it may be worth reviewing and, if necessary, modifying the invoicing processes in-house.
Based on our information, the IT transition from 2.0 to version 3.0 will be more time consuming than the process was during the switch from version 1.1 to version 2.0. The deadline of 1 April 2021 is a limitation period according to the current news, from that date, the HTA may fine taxpayers for incorrect (old version) data provision.
* * *
Should you need IT assistance in connection with the transition to NAV 3.0, VGD Hungary, with the help of its IT partner company, will be happy to assist you with issues related to IT developments related to real-time data provision.
Should you have any questions regarding the contents of this newsletter, VGD Hungary’s tax experts are gladly at your disposal.
