According to a previous communication of the Ministry of Finance, there was a sanction-free period until 30 June 2021 for non- or inadequate compliance with real-time reporting obligations, if the customer issued the invoices through self-billing and the customer has not been established in Hungary and does not have (and should not have) a Hungarian VAT registration.

Before the end of the sanction-free period, NGM-Decree No. 23/2014 (VI.30) on the tax identification of invoices and receipts, and on the supervision by the Tax Authority of electronically stored invoices (hereinafter: “Decree”) has been amended. The amendments are applicable as of 26 June 2021.

The amended rules of the Decree explicitly state that for invoices issued through self-billing by a taxable person, whose seat is not located in Hungary and who is not VAT-registered in Hungary in connection with the transaction subject to self-billing, it is possible to fulfil the real-time reporting obligations from a computer system other than the invoicing software of the taxable person issuing the invoices through self-billing. However, it is still a requirement that the real-time reporting is fulfilled with a machine-to-machine communication electronically.

The real-time reporting obligations concerning invoices issued through self-billing in the above case are to be fulfilled within 6 days following the issuance of invoices.

If you have any questions or you are interested in KPMG's online invoice reporting solutions, please do not hesitate to contact us.