Hungarian Legislation FAQ

Q: Sales transactions must be reported to invoice reporting system. What exchange rate must the transaction use?

• A: Once the company will be registered in Hungary and issue invoice with its Hungarian tax number the issued invoices must be compliant with Hungarian rules.

  According to the legislation, it is possible to use the mid-exchange rate quoted by the selected bank (the average of foreign currency buying and selling foreign exchange rates).

Q: Is it also mandatory to get the currency exchange rate from Magyar Nemzeti Bank for this transaction?

• A: The official foreign exchange rate published by the Hungarian National Bank („MNB”), and in some cases the foreign currency selling rate of the financial institution or the official exchange rate published by the European Central Bank („EKB) can be used. foreign currency exchange rate. However the FX rate of MNB is the most commonly used.

   

  If the company chooses the MNB or EKB FX rate it must be reported to tax authority during the VAT registration process.

Q: What transactions are subject to data disclosure on invoices?

• A: The following transactions are subject to data disclosure on invoices:

  • transactions carried out for consideration within the territory of the country by a domestic VAT liable person, including tax-exempt transactions and transactions subject to so-called domestic reverse charge procedure[5];

  • in the case of goods dispatched and transported as a domestic consignment, duty-free intra-Community supplies and (export) sales outside the Community;

  • distance sales from Hungary to another Member State of the Community, if a VAT liability arises in Hungary due to the circumstances of the transaction;

  • distance sales from another Member State of the Community to Hungary, if a VAT liability arises in Hungary due to the circumstances of the transaction;

  • on the supply of goods or services effected by a domestic VAT liable person in another Member State of the Community outside the territorial scope of VAT, if the buyer is obliged to pay the VAT after the transaction (except in the case of self-billing);

  • in the case of a transaction carried out outside the territory of the Community by a VAT liable person established in Hungary or having a fix establishment most directly involved in the supply outside the territorial scope of VAT; [8]

  -supply of goods or services effected domestically by a non-resident VAT liable person, if the buyer of the goods, the recipient of the service is not obliged to pay VAT.

Q: Are there any invoices that are exempted from being reported to NAV real time invoice data reporting (onlineszamla) ?

• A: Yes, there is no need to disclose data on invoices about:

  • intra-Community acquisitions and imports of products with a domestic place of supply;

  • the supply of goods or services effected domestically by a non-domestic VAT liable person, if the domestic VAT liable person buying the product and receiving the service is obliged to pay VAT;

  • services which may be supplied remotely by a non-resident VAT liable person within the territory of the country where the VAT liable person is registered in the one-stop system in another Member State for the payment of VAT on those transactions;

  • supply of goods or services effected by a domestic VAT liable person outside the territorial scope of VAT in another Member State of the Community, if the buyer, recipient is obliged to pay the VAT on the transaction and the invoice is made out by the buyer of the goods, recipient of the services on the basis of an authorization;

  • services which may be supplied remotely in another Member State of the Community by a VAT liable person not established in the territory of the Community or who is not established in the territory of the Community, provided that the VAT liable person fulfils his obligation to pay VAT on those transactions using the one-stop system;

  • a transaction performed outside the territorial scope of the Act on VAT, if the fix business of the VAT liable person performing the transaction or the fix establishment most directly involved in the supply is not located domestically;

  • on distance sales effected from Hungary, if after the transaction (either due to the decision of the VAT liable person or due to exceeding the value limit) no VAT liability arises in Hungary;

  • purchase document in the case of agricultural activity entitling to a compensatory premium.

 Q: Where can entities do a vendor registry check for Hungarian vendors?

• A: this can be done through NAV via Szolgáltatások > Adózó lekérdező.

Q: The VAT report names in Hungary are updated each year. For example from 2165A for 2021 and 2265A for 2022.

If for example a company has not yet submitted a VAT report for December 2021 and the form has already been updated to 2265A for the current year.

Will they be required to submit the VAT report using the 2165A form or the 2265A form?

• You are not able to submit VAT for 2021 on the 2265A form. All VAT returns have to be submitted on the related year’s form. You are not able to change the year of the periods on the form. It is same in case of 22A60 and 2265M as well. This applies to all VAT reports.