New online invoice data reporting requirements in 2018

 As of 1 July 2018 invoices that are issued with an invoicing software and have a VAT content of at least HUF 100,000 must be reported by means of online data provision to the tax authority. The new regulation will enable the tax authority to directly monitor the operation of invoicing software used by taxpayers, furthermore it will ensure direct data analysis as well.
Taxpayers must report to the National Tax and Customs Authority, electronically, at least the mandatory data prescribed by the VAT Act for the invoices and documents in lieu of an invoice issued by invoicing software, in a pre-defined file format, either immediately or within 24 hours.
Taxpayers must electronically report at least the mandatory data content, as prescribed by the VAT Act, of invoices and correction documents issued by invoicing software to NAV, in XML format, in a predefined manner and data structure, immediately at the time of issue. In this case, the time of issue is when the invoicing software finalizes the data of the document issued.
The provision of the data must be carried out via an electronic data processing method developed for this purpose. The structure in which data is to be provided will be available as Schedule No. 4 of Decree No. 23/2014 (VI.30.) of the Ministry for National Economy.
Prerequisite for commencing data provision is that the tax authority must register the taxpayer, based on the taxpayer’s prior notification concerning the data enabling the use of the machine-to-machine interface (i.e. data pertaining to technical users, as defined further below).
It has also been clarified that the data provision obligation is deemed fulfilled once the data reporting has been performed according to the regulations, and NAV’s system has confirmed the successful processing of the data. If the data processing was unsuccessful, the data must be submitted again after fixing the error.
It is important to note that if the taxpayer realizes that the data provision was not successful, despite a confirmation of successful processing, the data must be submitted again. However, in this case the taxpayer’s explicit approval in NAV’s system is also required.
In the above cases of incorrect data reporting, the corrected data can also be provided by manually entering the invoice data into NAV’s system. Manual data provision is mandatory if the taxpayer is unable to resolve the error that prevents successful data processing within three working days of the error’s discovery.
NAV will post a notice on its website informing taxpayers of any malfunction or system maintenance. After the error has been resolved, the data reporting must be performed electronically within 24 hours. The same applies to a malfunction in the taxpayer’s system; however, according to a new rule, if there is a malfunction or insufficient internet coverage at the taxpayer for more than 48 hours, the taxpayer must notify NAV of this fact at the expiration of the 48 hours at the latest, and the data provision must be performed within 24 hours by manually entering the invoice data into NAV’s system.
According to the published technical specifications, it is possible to create primary, secondary and technical users in NAV’s system. Primary and secondary users (“web users”) can manage the dedicated website, while only a technical user may perform the reporting.
Usernames and passwords are assigned to all types of users, but technical users also have signature keys and exchange keys. The web interface establishes communication by sending a token encrypted with the exchange key belonging to the technical user who initiated the communication.
The token is valid for five minutes after the communication request, and it enables the taxpayer to send all invoices created within this timeframe in one communication (a maximum of 100 invoices, each in its own XML file). The successful receipt of the data inside the token is indicated by a confirmation, a “transaction ID”. However, this does not mean that the reporting obligation has been fulfilled; the invoice data content must be checked first. The status of the transaction can be queried by the transaction ID, without limitation to the number or frequency of the querying). The report contains messages of approval or rejection of each invoice after they have been reviewed.
 
If you think you are not sufficiently prepared to comply with the online data provision obligation, our experts can help you interpret the regulations in detail or assist in the automation of fulfilling the respective obligations.