As provided for in Annex No. 10 of the Act CXXVII of 2007 on value added tax that is effective as of the 1st of July, 2020; the taxpayer is subject to data disclosure obligation regarding its invoices that are issued of the transactions between domestic taxpayers regardless of whether contain value added tax.

Reporting Obligation

The abovementioned data disclosure obligation can be discharged via the the Online Invoice interface.

Manual Invoicing

Beyond that date, issuing invoices by hand may not become forbidden, but in the case handwritten invoice with the application of a form (e.g. a block of invoices), the data disclosure must be performed within 4 calendar days in such a way that data must be recorded on a website.

However, if such an invoice contains output tax of HUF 500,000 or even more, the data disclosure must be performed on the day following the day when the invoice was issued.  From our point of view, recording the data content of a handwritten invoice on the above mentioned website causes too big administrative burden for the taxpayer, for this reason it is recommended to opt for applying invoicing software.

Cash Register

Fortunately, there are lots of types of cash registers available on the market today, so a cash register operated in a retail store may also be suitable for issuing invoices. Thus, a taxpayer may be able to make out invoices with a cash register which is a relatively simple method for this aim.

Based on Section 178 (1) (a) of the VAT Act, where the obligation of issuing receipts is satisfied with cash register, the taxpayer regularly supplies data about the receipts + invoices made out with cash register + other related data of the cash register. Invoices made out by cash registers are not subject to the online data supply regime on invoices applicable from 1 July 2020. The obligation of online cash register operators will not be amended from the date referred, i.e. the cash register will continue to provide the Tax Authority with data on invoices made out by the cash register. It is a very good point.

Billing systems

However, a taxpayer who issues an invoice for another domestic taxable person by an invoice program or using a printed invoice form and simultaneously registers the amount of the invoice into the cash register as well, shall not be exempted from the obligation of providing with the Tax Authority the online invoice data.

Given that the data of the sales are reflected in the reporting of both the cash register and the invoicing programme (or manual recording), it would be advisable to review this practice in order to avoid problems arising from the performance of double reporting.

In this case, we recommend to issue another cash flow document instead of sales note (receipt), since financial flows i.e. cash received or paid have to be certified always by any cash flow documents.

Ildikó Hajnal-Balázs

Senior Tax Consultant | Accace Hungary

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