18 - 16 Basic Rules of Issuing Invoices and Receipts (01.09.2023)
18 - 16 Basic Rules of Issuing Invoices and Receipts (01.09.2023)
The VAT taxable persons shall ensure that an invoice is issued in respect of all supplies of
goods or services. This information booklet describes the basic rules for this. The
requirements pertaining to invoicing are contained in Act CXXVII of 2007 on Value Added
Tax (hereinafter referred to as VAT Act)1 and the decrees issued based on this act.2
1. Invoicing Obligation
The taxable person shall ensure that an invoice is issued in respect of all supplies of
goods or services which he has made in the domestic territory for consideration
according to the general rule of the VAT Act to the customer (if a person or organization
other than the taxable person).3 As stated in the VAT Act, this invoicing obligation relates
to the completion of a transaction (and not to the payment obligation of the customer to
whom the products or services are supplied).
The invoicing obligation stated in the VAT Act does not extend to cases, which do not
qualify as supply of products or services by the taxable person for the purposes of the VAT
Act, i.e. e.g. no invoice needs to be issued for exercising executive powers, for
compensation payment, or for legal costs granted by the court (etc.), specified in Section
7 of the VAT Act.
However, unless otherwise provided in the VAT Act, the invoicing obligation pertains
also to transactions that are free of charge but, for the purposes of the VAT Act, they
qualify as the supply of products or goods for consideration.4 (Naturally the VAT taxable
person is obliged to issue an invoice even in those cases, if the products and services are
supplied to a person or organisation, other than the taxable person.)
Considering that a VAT liability is generated at the time of obtaining the advance – as a
general rule –, an invoicing obligation is also linked to the acquisition of a pecuniary
advantage of supply of products, services that can be included in their consideration, i.e.
an advance provided on the basis of an agreement between the parties. 5 The invoice
issued for the received advance shall contain the data of the supply of goods and services
for the consideration of which the advance may be included.6
The obligation to issue invoices on payments on account is not general in nature. It does
not cover advances included in the consideration for tax-free intra-Community supplies
of goods.7 There is no obligation to issue invoices on payments on account paid by non-
legal non-taxable persons if the amount of payment on account (containing the tax also)
is less than 900,000 HUF if the purchaser of the product or service does not request an
invoice to be issued on the payment on account. If the advance payment is HUF 900,000
or more, invoicing is obligatory, regardless of the request of the purchaser of the product
or the recipient of the service.8
There is also an obligation to issue invoices in the case of the supply of goods and
services performed abroad, if the taxable person has a place of residence for economic
purposes most directly affected by the performance of the transaction or in the absence
of such a place his permanent address or usual place of residence. In order to invoice a
transaction performed abroad, the VAT in the case of a transaction carried out in another
Member State of the European Community (hereinafter referred to as the Community), an
additional condition is that the supply of goods or services is subject to reverse charge
in the Member State of performance, i.e. the obligation to pay tax after the transaction
should not be borne by the person obliged to issue a domestic invoice, but by the
purchaser of goods and services in another Member State).9
The obligation to issue an invoice means not only the production of the invoice, but also
its transfer or delivery to its addressee, i.e. the purchaser of the goods or services.
4 Section 11(1)-(2) and Section 14(1)-(2), and cases of Section 12 and 18/A of the VAT Act.
5 Section 159(2) a) and b) of the VAT Act.
6 Section 159(3) of the VAT Act.
7 Section 159(4) of the VAT Act.
8 Section 159(2) b) of the VAT Act.
9 Section 159(2) c) and d) of the VAT Act.
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1.1 According to the Hungarian rules when is the invoicing obligation to be fulfilled?
Not the rules on invoicing of the VAT Act shall apply in case of the supplies of products,
services provided domestically, for which the tax payment and tax return obligations are
performed by a taxable person who has registered in the one-stop shop in another
Member State of the Community.12
Even though the supply is made within the domestic territory, the provisions of the
VAT Act pertaining to invoices must be applied in the following cases:
- if the place of supply is deemed to be outside the Community pursuant to the
provisions of the VAT Act and the established business of the supplier or his fixed
establishment that is most directly involved in the transaction or, in the absence of
such a place of business, permanent address or usual residence is inland,13 or
- if the seat of the business activities of the tax subject who performs the transaction, or
their established permanent site most directly involved in the performance in the lack
of that, the permanent address or usual dwelling place is located inland, but the place
of supply pursuant to the VAT Act is deemed to be in another Member State and has
tax payment obligation is accrued by the purchaser of the product or the recipient of
the service provided that not self-invoicing occurs14
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A taxable person is exempt from invoicing in relation to any supply of goods and
services which is tax exempt in view of the public interest or special nature of the
activity,16 providing that the taxable person issues a document17 for the transaction
in compliance with the provisions of the Accounting Act.18 The accounting document
of such a transaction – e.g. tax-free renting of a property or provision of financial services
– must therefore comply with the provisions of the Accounting Act. This must also apply
if the taxable person includes the name of the invoice on the receipt, or issues it on an
invoicing form or by using of an invoicing programme. The continuity of the serial
numbering of the invoicing program is not impaired if the invoice and the accounting
document are issued in the same serial number range. 19 This exemption from invoicing
obligation will not lead to an obligation for the supply of the issue a receipt.20
The following tax-exempt transactions will not be exempted from the obligation to
issue an invoice, i.e. no accounting document can be issued instead of an invoice:
- other tax-free education due to its public interest nature,21
- the tax-free transaction of a dentist or dental technician due to its public interest nature,
- the tax-free healthcare activity provided by a non-public service operator due to its
public interest nature,
- the tax-free service of a cooperating community due to its public interest nature,
- the tax-free real estate sales due to its special nature.22
In case the acquirer of a service whether tax subject or not does not request it, no
invoice needs to be issued on tax exempt international air passenger transport with
a foreign place of departure or arrival.23 In the lack of a request for the issue of an invoice
by the acquirer of the service, the tax subject must issue an accounting record in
accordance with the provisions of the Act on Accounting. In case the acquirer of the service
does request the issue of an invoice, an invoice must be issued in accordance with the
provisions of the VAT Act and the legal regulation issued on the basis of its authorization.24
Below the limit of HUF 900,000, inclusive of VAT, the taxable person shall be exempted
from the invoicing obligation if the customer is a non-taxable person apart from non-
taxable legal persons who pays the consideration inclusive VAT, by the date of supply,
without requesting an invoice from the taxable person. 25 The taxable person, if
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exempted from the obligation of invoicing, shall ensure that a receipt is issued to the
customer.26
The taxable person is exempt from the obligation to issue an invoice also if the non-
taxable person excluding non-taxable legal persons makes an advance payment of less
than HUF 900,000 and does not request an invoice. If the taxable person is exempted
from the obligation of invoicing for such a reason, they are not obliged to issue a receipt
on the received advance payment.
The fact that such an advance is not subject to an obligation to issue an invoice or receipt
does not mean that there is no supporting document for the provision, receipt or crediting
of the advance under other legislation, such as the Accounting Act. If the advance is
provided by the transfer of cash, a cash substitute payment instrument, a non-cash
payment instrument or other property, such as a product, the transfer of the advance must
be documented, which may be done, for example, by an accounting document issued by
the recipient of the advance. If the advance is paid by bank transfer, the transfer of funds
may be documented, for example, by a bank receipt.
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- supply of goods or services to a VAT non-taxable person (who is not a legal person
either), which consideration, inclusive VAT, is paid in any way by the date of supply,
providing that the consideration, inclusive of VAT, is less than HUF 900,000, and the
customer requests an invoice.35
- the supply of goods or services to a VAT non-taxable person (who is not a legal person
either), the consideration for which is not (necessarily) paid by the date of supply.36
- tax exempted international air passenger transport service37, provided that the user of
the service – whether taxable person or not – requests the issue of an invoice38
- Intra-Community supply of goods39, including also the inter-Community sale of any new
transport means by a taxable person under the Section 6(4) a) of the VAT Act40
- Distance sales41 with the exception of the cases if the taxable person performs the tax
return and tax payment obligations in one-stop shop system. If the latter is the case the
issue shall be issued on the request of the buyer.42
- sale of a real property in a series of transactions,43
- supplies of goods or services outside the territory of the Community, provided that the
taxable person has established his business that is most directly involved in the
transaction in question inside the domestic territory or, in the absence of such a place
of business, has his permanent address or usually resides inside the domestic
territory,44
- supplies of goods or services made in another Member State within the territory of the
Community, and the person liable for the payment of the VAT is the person to whom
the goods or services are supplied, provided that supplier taxable person has
established his business that is most directly involved in the transaction in question
inside the domestic territory or, in the absence of such a place of business, has his
permanent address or usually resides inside the domestic territory.45
According to the main rule an invoice must be issued by the chargeable event according
to the VAT Act by the receipt and credit of payments on account or within46 a reasonable
timeframe.
Considering the reasonable time determined in the VAT Act the invoice must be
issued:
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An invoice may be issued either by the supplier himself i.e., the VAT taxable person
supplying the goods or services or, in his name and on his behalf, by an agent of his
choice. In the latter case, the supplier (obligor) and the agent must agree in advance in
47 Section 163(2) b) of the VAT Act. Before 15 July 2023, the obligation to issue an invoice immediately was
applied, with the exceptions mentioned above, to cases where the consideration had been paid in cash or
by a cash substitute payment instrument.
48 Act CL of 2017 on the Rules of Taxation (hereinafter referred to as Art.).
49 Section 163(2) b) of the VAT Act.
50 Section 163(2) b) of the VAT Act. Before 15 July 2023, the obligation to issue an invoice immediately was
applied, with the exceptions mentioned above, to cases where the consideration had been paid in cash or
by a cash substitute payment instrument.
51 Section 163(2) b) of the VAT Act.
52 Section 163(2) a) of the VAT Act.
53 Section 163(2) a) of the VAT Act.
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writing, laying down, in particular, the terms and conditions for the issue of invoices.54 A
power of attorney for invoicing services may be made out pertaining to invoicing
procedures for a single transaction only, or for compliance with invoicing obligations on
a general basis.55 A power of attorney shall be made in writing.
An invoice may be issued on behalf of the supplier by the customer, the person to whom
goods or services are supplied, or by a third party (agent). The agent must issue the
invoice in the name of the supplier i.e. the obligor/principal. Invoices shall contain: the
words “önszámlázás” (“self-invoicing”) where the customer receiving the goods or
services issues the invoice as an agent.56
In the case of invoice issued on paper by the person or organization authorized by the
party with the invoice issue obligations, the authorized party sends a copy of the invoice
to the person having the obligation without delay. In the case of an electronically issued
invoice, the invoice is made available to the obliged party electronically and without delay.
In case of invoices created with an online program, the party obliged and the person
authorized by them must have a prior written agreement about the range of invoice serial
numbers, too, to use when invoices are created, which range must also be recorded in a
registry kept by the obliged party 59 . Besides the contents defined in the VAT Act, the
Decree on Invoices issued on the basis of the VAT Act, and the Civil Code 60 , the
authorization may contain any issues considered important by the parties.
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2. The Invoice
An invoice is any document that meets the conditions laid down in Chapter X. of the VAT
Act. Any document or message, other than the documents that amends61 and refers
specifically and unambiguously to the initial invoice and that meets the conditions
laid down in the VAT Act62 shall be treated as an invoice. In the case of taxable persons
established in any Member State of the Community other than Hungary, the invoice63 is a
document issued on the supply of goods and/or services, that is considered equivalent to
Sections 226-231 and 238-240 of the VAT Directive 64 in the Member State of the
Community where established according to the national law of that Member State of the
Community.65
Pursuant to the provisions of the VAT Act,66 the authenticity of the origin, the integrity
of the content and the legibility of an invoice shall be ensured from the time of issue
until the end of the period for storage of the invoice. ‘Authenticity of the origin’ means
the assurance of the identity of the supplier or the issuer of the invoice.67 ‘Integrity of the
content’ means that the content of the invoice required by the VAT Act has not been
altered.68 ‘Legibility of the invoice’ means that the invoice must be readable without any
thorough investigation or explanation. Pursuant to the general rule69 pertaining to that
obligation, the requirements of the authenticity of the origin, the integrity of the content
and legibility may be satisfied by any business controls which create a reliable audit trail
between an invoice and a supply of goods or services. The persons issuing and receiving
an invoice both must fulfil the requirement pertaining to the authenticity of the origin and
integrity of the content. The parties can satisfy the requirement also irrespective of each
other.
The business controls referred to in the VAT Act indicate a very wide concept. The
business controls refer to any procedure, which is applied by the taxable person in order
to verify the invoice against his own financial claims and obligations. It is an important
aspect of business controls that the invoice is controlled within the business and
accounting process and is not managed as an independent separate document. The
taxable person selects and elaborates his own business controls and, in the procedure
verifies primarily, as the person issuing and accepting an invoice in his own interest:
- whether the invoice is substantially acceptable, i.e. the transaction indicated in it was
fulfilled in the quantity and quality stated in the invoice,
and, as the person accepting the invoice,
- he checks whether the claim of the issuer of the invoice is actually the same as stated
in the invoice,
deduction by the taxable person receiving it under Section 127 of the VAT Act.
64 Council Directive 2006/112/EC of 28 November 2006 on the common system of value added
tax.
65 Section 168(3) of the VAT Act.
66 Section 168/A (1) of the VAT Act.
67 Section 259 6/A. of the VAT Act.
68 Section 259 1/A. of the VAT Act.
69 Section 168/A (2) of the VAT Act.
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- if the bank account number stated by the issuer of the invoice is accurate and other
items of the invoice in order to make sure that only those invoices will be paid that are
his obligations to pay.
An invoice may be issued electronically or in paper-based form.70 According to the
definition in the VAT Act 71 , an electronic invoice is an invoice that contains the
information required in the VAT Act, and which has been issued and received in any
electronic format. Therefore, the invoice sent only in email also qualifies as an electronic
invoice without consideration to the issue whether the data of the invoice are generated
and inserted into the electronic message directly from an invoicing program or if the
invoice is a scanned copy of the paper-based version). The general rules applicable to
invoices also apply to electronic invoices.
However, considering that the customer (the purchaser of the product, the recipient of
the service) to whom the goods or services are supplied has technical requirements, too,
the cooperation of the parties is a fundamental requirement in electronic invoicing.
Consequently, as a further condition of issuing an electronic invoice, the VAT Act requires
the consent of the person accepting the invoice (which may not be only formal consent,
but can also be an implicit consent by paying the consideration stated in the invoice) as
well as a prior written agreement of the parties on the application of the EDI system.72
The electronic invoice must be kept in electronic form, both as an invoice issuer and
as an invoice recipient.73. In case of an audit by the tax authority, it must be made available
in accordance with the provisions of the Decree on Invoices that had been referred to, that
is
- the information of the invoice kept in an xml format must be presentable in accordance
with the annex 2 of the Decree on Invoices and in a data structure given in annex 3,
- the information of the invoice kept in any other electronic format must be presentable
in accordance with the annex 2 of the Decree on Invoices and in a data structure given
in annex 3 or in pdf format.74
The VAT Act specifies two procedures where, based on the power of the law, it is
obvious that the electronic invoice fulfils the requirements of the authenticity, of
the origin and the integrity of the content.75
Such invoices are as follows:
- an invoice containing a qualified electronic signature,
- any invoice made or sent by EDI electronic data.
For such electronic invoices the persons issuing and accepting the invoice do not need to
apply business controls according to the requirements of the VAT Act. Naturally, a taxable
person may conduct such business controls in such cases too, especially considering that
such controls serve the economic interests of the taxable person (even irrespective of the
provisions of the VAT Act). For other electronic invoices (as for paper invoices), the
integrity of data and the authenticity of the origin can be substantiated typically with
business controls.
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In case of invoices issued by cash registers, shall apply the provisions of Decree on Cash
Registers in addition to the rules of the VAT Act relating to invoicing.
When an invoice is issued with an invoicing program, shall apply the provisions of
Decree on Cash Registers in addition to the provisions of VAT Act on invoicing. Thus,
among others, the followings: The invoicing program must allocate consecutive serial
numbers without any omission or repetition.77
The copy remaining at the issuer of the invoice issued with an invoicing program and
printed on paper may also be maintained as an electronic file provided that it is kept in
accordance with the requirements 78 of electronic archiving. 79 The invoicing program
must have a function called "data disclosure for inspection by the tax authority", which
can be started to export data during a possible tax audit.80
The invoicing program shall meet the requirement to be able to provide the online data
disclosure of the mandatory data content of the invoices issued and documents treated
as invoices to the NTCA.81 A receipt which pursuant to the Point 1 of the Annex 10 of the
VAT Act is the subject of the online data disclosure obligation, cannot be issued with an
invoicing program that cannot provide an online data disclosure
➢ Additional useful information about the online data disclosure can be found in the
information booklet ‘Rules on invoice data disclosure effective from 4 January
2021’at the link https://nav.gov.hu/ado/afa/A_szamlakibocsatok_sz20201231
[available in Hungarian only].
Invoices may be issued in Hungarian or in any spoken foreign language.82 If the invoice
is issued in a language other than Hungarian, during an audit conducted within the
framework of administrative tax proceedings, the taxable person issuing the invoice may
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The VAT Act defines the mandatory contents of the invoices, i.e. the data that must be
included in an invoice in order to comply with the requirements of the VAT Act. Apart
from the mandatory data, any other data may also be indicated in an invoice according to
a statutory obligation, the agreement of the parties, or the decision of the issuer.
Mandatory data contained in an invoice84:
a) invoice data:
- the date of issue;
- a sequential number, which uniquely identifies the invoice;
b) identification data of the supplier of the goods or services:
- the tax number under which the taxable person supplied the goods or services in the
case of a group VAT taxation arrangement, in addition to the tax number of the
member performing the transaction, the group identification number 85,
- the full name and address,
c) identification data of the customer:
- the full name and address,
- the tax number in case of reverse taxation under which the customer received a supply
of goods or services in respect of which he is liable for payment of value added tax, or
- in the case of tax-free intra-Community sales, the (Community) tax number of the
other Member State under which the customer received the intra Community supply
of goods, or
- the first eight digits of the customer’s tax number or of the group identification
number in connection with a group VAT taxation arrangement under which the
taxable person registered in the domestic territory received a supply of goods or
services, provided that the supplier of the goods and/or services has established his
business in the domestic territory (or in the absence of such a place of business, has
his permanent address or usually resides in the domestic territory);
d) data of the supply of goods/services:
- the name and the quantity of the goods sold, or the name and the quantity of the
service provided that it can be expressed in some natural unit of measurement;
- the date of supply or the date of receipt, credit or acceptance of the advance, if other
than the date of issue of the invoice;
- the taxable amount, the unit price of goods exclusive of tax or the unit price of services
exclusive of tax, if it can be expressed in some natural unit of measurement, and any
discounts or rebates if they are not included in the unit price;
- the tax rate applied;
- the amount of the output tax, except where, in accordance with the VAT Act, such a
detail is excluded;
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- in the case of tax exemption, reference to the applicable provision of the VAT Act or
the VAT Directive, or any other reference indicating that the supply of goods or
services is exempt;
e) data to be indicated in relation with special provisions of the VAT Act:
- the term “fordított adózás” (“reverse charge procedure”) where the customer is liable
for payment of VAT;
- in the case of the tax exempt Intra-Community supply of a new transport vehicle, the
data related to new transport vehicles determined by the VAT Act86;
- the term “pénzforgalmi elszámolás” (“cash accounting”) when using the special
taxation scheme defined under Chapter XIII/A;
- the term “önszámlázás” (“self-invoicing”) where the customer (as the authorized
person) receiving a supply of goods or services issues the invoice;
- in connection with the activities of tour operators governed under the special
provisions of Chapter XV of the VAT Act, the words “különbözet szerinti szabályozás -
utazási irodák” (“margin scheme - travel agents”)
- where one of the special arrangements applicable to second-hand goods, works of art,
collectors’ items and antiques is applied under the special provisions of Chapter XVI
of the VAT Act, the term “különbözet szerinti szabályozás - használt cikkek” (“margin
scheme - second-hand goods”); “különbözet szerinti szabályozás - műalkotások”
(“margin scheme - works of art”) or “különbözet szerinti szabályozás -
gyűjteménydarabok és régiségek” (“margin scheme - collector’s items and antiques”)
respectively
- where a financial representative is involved, the name, address and tax number of the
financial representative.
As a general rule, the invoice shall indicate the output tax amount payable in HUF even
in the case where all other details are expressed in another currency.87 An exception to
this rule is an invoice issued by the taxable person under the rules of the VAT Act for the
supply of goods or services outside the country.88
If the tax base is expressed in any foreign currency, the tax must be converted into HUF in
compliance with Sections 80 and 80/A of the VAT Act. The exchange rate applicable shall
be an exchange rate which is quoted by a credit institution authorized in the domestic
territory to engage in money exchange operations as the selling rate; or is officially quoted
by the National Bank of Hungary (hereinafter referred to as “NBH”) or the European
Central Bank (hereinafter referred to as “ECB”). The NBH or ECB exchange rate may be
applied only if the taxable person has previously notified the National Tax and Customs
Administration (notification form, change reporting form) of his decision to choose the
NBH or ECB exchange rate in advance (the NBH and ECB exchange rate together cannot
be used). Apart from the applicable exchange rate, the VAT Act also defines the exchange
rate, effective on a specific date that must be applied for the HUF conversion.89 According
to the general rule, the exchange rate, effective on the date of supply according to the
provisions of the VAT Act must be used.
for a transaction carried out in Hungary was clarified by the amendment to Section 172 of the VAT Act,
which entered into force on 24 November 2022.
89 Section 80(1) of the VAT Act.
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The invoice issued for the advance shall contain the data of the supply of goods or
services to which the payment on account pertains in terms of the consideration
payable.90
The domestic taxable person supplying of goods or service must indicate the
Community tax number in another Member State of the person to whom the
products or services are supplied, if
- the transaction is a tax exempt intra-Community supply of goods (for which the
customer is liable for the payment of tax under the title of intra-Community purchase
of goods),
- a supply of goods in another Member State (e.g. sale of products for installation or
assembly) or is a supply of service in another Member State [e.g. pursuant to Section
37(1) of the VAT Act], for which the person to whom the services supplied is obliged
to pay the tax.
The domestic taxable person supplying of goods must indicate the first eight digits of
the tax number of the domestic customer to whom the products or services are
supplied, if the person to whom the products and servicesis VAT taxable person reistered
domestically and acts in the transaction as such a person.
A foreign company/entrepreneur registered as a domestic VAT taxable person without an
established business in the domestic territory or in the absence of such a place of business,
a permanent address or place of residence is exempted from this obligation. But the
indication of the tax number of the domestic taxable person receiving the goods or
services in the invoice is practical in such cases too.
Image of Utility Invoices, in the Act CIII of 2011 on the Public Health Product Tax and in the Act LXVIII of
2016 on the Excise Tax.
93 Section 177 of the VAT Act.
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required in acts other than the VAT Act, or they are contained erroneously, such a mistake
or deficiency of the invoice does not affect the receiver’s right of deduction.
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the customer (i.e. the data specified in Section 2.1. sub-paragraphs a)-c)), but also the
following data must be indicated:102
- the designation and quantity of the goods supplied, or the designation of the services
rendered and the quantity of it, if it can be expressed in some natural unit of
measurement;
- the date of supply if other than the date of issue of the invoice;
- the monetary amount of the consideration,
- the term “fordított adózás” (“reverse charge procedure”) where the customer is liable
for payment of VAT;
In relation to the obligatory content of a simplified invoice, specified by law, it should be
noted that data, other than those specified in the VAT Act, may also be indicated in the
receipt.
An aggregate invoice may be issued103 if the taxable person provides supplies to the same
person or organization for which an invoice is to be issued, compliance with the invoicing
obligation may be ensured by the issue of a single invoice covering the said transactions
- simultaneously with the chargeable event, or
- during the particular calendar month or the respective tax assessment period.
The issuer of the invoice may decide to issue an aggregate invoice for transactions
completed on the same day without any specific agreement. The invoicing obligation must
be fulfilled on the date of the chargeable event, but not later than within a reasonable
timeframe.
An aggregate invoice may be issued for transactions not completed on the same date only
if the parties had a prior agreement on the issue of the aggregate invoice.104 An aggregate
invoice may be issued for a maximum of the transactions carried out in a given calendar
month or in a given tax assessment period by the person liable to issue the invoice. An
aggregate invoice – subject to an agreement of the parties – may be issued also for a period
shorter than a calendar month, or the tax assessment period of the person obliged to issue
to the invoice (e.g. a taxable person preparing monthly declaration may issue aggregate
invoices for a week)]. If the person obliged to issue the invoice does not submit
declarations monthly, the aggregate invoice issued by him may relate to a period, longer
than one calendar month, or to a period, starting in one calendar month and ending in
another calendar month, if the aggregate invoice does not contain:
- any supply of goods referred to in Section 89 of the VAT Act, i.e. tax exempt intra-
Community supply, and
- supply of goods which pursuant to Section 37(1) of the VAT Act, is performed in
another Member State of the Community.105
For any aggregate invoice to be issued for transactions not completed on the same day,
the timeframe available for the issue of the invoice must be calculated from the last day of
the calendar month, or from the last day of the tax assessment period pertaining to the
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taxable person obliged to issue the invoice. Consequently – according to general rule – a
taxable person preparing monthly declarations must issue an aggregate invoice no later
than on the 8th day following the last day of the calendar month.106
The aggregate invoice shall list all chargeable (issuable) transactions separately,
showing the taxable amount of each transaction - classified according to the applied tax
rate and legal titles for tax exemptions - the total of these items separately.107 With respect
to the aggregate invoice itself, no date of completion can be interpreted, only the
transactions on the aggregate invoice have date of completion. The date of
completion of each transaction must be indicated in the aggregate invoice. All other
aspects of aggregate invoices shall be governed by the relevant provisions pertaining to
invoices.108
Any document that modifies the data content of a given invoice without any doubt by
reference to a given invoice is treated to be a document under consideration with an
invoice.109 Consequently, the document in lieu of an invoice is a collective name for all
documents that modify any data of, and refer to, a previously issued invoice. Thus, the
concept of a document in lieu of an invoice is a document containing a correction or
supplementation of any data other than the tax base or tax amount made in the original
invoice. For example documents which modify the inadequate code, or the erroneous date
of supply.
If any data of an original invoice issued for a transaction is subsequently altered with a
document in lieu of an invoice, then the invoice and the document in lieu of the invoice
together will constitute the document for the transaction. The invoice containing the error
or inadequacy does not need to be returned to the issuer, and the issuer must be requested
only to correct the error or inadequacy with a document in lieu of an invoice.
If the invoice is printed or manually issued it is not objectionable in case of error regarding
tax or taxable amount the crossing the erroneous data (beside remaining the original data
legible) and signing, overwriting or supplementing the correct data, filling in the missing
data and the signature of the person making the correction, indicating the date of the
correction in all copies of the invoice. It is possible to change the manual invoice with a
machine invoice, and vice versa. However, there is no possibility for the taxable person to
correct the machine invoice by handwriting.
A single document in lieu of an invoice cannot be used for correcting an error where the
invoice was not issued to the actual customer and there is another taxable person with a
similar name. In such cases the erroneously prepared invoice must be cancelled with a
document in lieu of an invoice and an invoice needs to be issued to the actual customer.
The document in lieu of an invoice does not need to be issued, sent to the erroneous
recipient of the invoice in case the tax subject perceives the mistake before the delivery to
the intended recipient or if the invoice is sent back by the erroneous recipient. In such
cases, it is sufficient for the person obliged to issue the invoice to invalidate the mistaken
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Since the VAT Act defines the minimum contents of a document in lieu of an invoice, the
taxable persons may also include any other data, deemed important by them.
The document in lieu of an invoice is governed by the provisions pertaining to invoices.111
Consequently, the integrity of the content, the authenticity of the origin and legibility are
also mandatory requirements for a document in lieu of an invoice, and any document in
lieu of an invoice issued by an invoicing software or by using an invoice book must also be
a document suitable for identification for tax administration purposes.
A taxable person may use one document in lieu of an invoice to modify several
invoices by clearly and transparently indicating references to all invoices to be modified
on the aggregate document of modification and the data of the particular invoices affected
by the modification, the nature of the modification and its mathematical effect (if any). If
the correction relates also to the tax base and/or tax amount indicated in the invoice, then
in the modification document the taxable person may modify only invoices issued for such
transactions, in relation to which the result of the tax and/or tax base correction must be
accounted within the same settlement period.
In practice taxable persons do not correct an error in an invoice by issuing a document in
lieu of an invoice but invalidate/cancel the previously issued defective invoice and issue
a new (defect-free) invoice. In such cases both the invalidating and the new invoice shall
contain the reference to the incorrect invoice. This technical solution of modifying an
invoice is described above does not affect the consideration of the modification of an
invoice according to Sections 77-78, 153/B-153/C., 170 and Annex 10 of the VAT Act; the
cancelled invoice and the new invoice together modify the data of the original invoice and
must together be used as a modification invoice.
4. Receipt
Below the limit of HUF 900,000, inclusive of VAT, the taxable person shall be
exempted from the invoicing obligation if the customer is a non-taxable person
other than non-taxable legal persons who/that pays the consideration, by the date of
supply without requesting an invoice from the taxable person112. In such cases the
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taxable person shall ensure that a receipt is issued to the customer receiving the goods
or services. 113 The taxable person may issue an invoice instead of a receipt.114
A receipt can be printed on paper or may be electronic. 115 It may only be issued in
Hungarian.116 Besides the stipulations of the VAT Act both printed receipts and receipts
generated by computers not including here receipts generated by means of a cash register
must conform to the provisions of the Decree on Invoicing.
Legal provisions determine those cases in which the tax subject must issue a receipt by
means of a cash register. If the tax subject issues receipt by means of a cash register either
as a result of the legally stipulated obligations or the basis of an own commitment the
stipulations of the Decree on Cash Registers must be taken into account. If the obligation
of the issue of a receipt is complied with by means of a cash register, cash registers capable
of online data connection are to be used regardless whether the use of the cash register is
the result of an own commitment or a legally stipulated obligation.
The taxable person can only be exempted from the obligation to issue a receipt based
on the basis of a legal stipulation g, exemption cannot be granted on an individual
permission.
Pursuant to the law, the taxable person shall not be required to issue a receipt in
connection with the following transactions:117
- supply of printed news materials;
- games of chance and gambling games under the Gambling Act118;
- the consideration inclusive VAT is paid to the person by use of unattended vending
machines according to Art.
The case mentioned in point c) is changed as of 1 January 2022. From this time on the
transactions performed through unattended vending machines cease to be generally
exempted from the obligation of issuing a receipt. According to point c) the taxable person
will be exempted from the obligation of issuing a receipt only in the case if the amount of
the consideration, including tax is reimbursed to the taxable person by the use of an
automatic device under Act on the Rules of Taxation.
The following taxable persons and businesses may fulfil their obligations to issue a
receipt only with a cash register:119
a) pharmacies,
b) According to TEÁOR 08 effective on 15 October 2009, all taxpayers, shop, mobile
shop performing the following activities:
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As of 24 November 2022, the VAT Act also contains a provision on the provision of data
on receipts issued by other technical equipment for issuing receipts in addition to cash
registers.121 On the same date, the Minister responsible for tax policy (i.e. the Minister of
Finance) was authorised to issue a decree regulating the provision of data, authorisation,
distribution, operation and control of other technical solutions for the issue of receipts
produced by other equipment.122
In the event that the receipt also gives the right to use the service specified therein, then
instead of the date of issue, it is sufficient to indicate the date or period on the receipt,
when the service specified therein can be used. 124
The non-taxable exempt person is also liable for issuing invoices and receipts. In
connection with the fulfilment of this obligation, it must be taken into account that the
taxable person carries out the transaction as an exempt person or not.126 For transactions
that the taxable person performs as non-exempt person the general rules of the VAT Act
on invoicing shall apply.
As an exempt person, the taxable person can fulfil that obligation only with invoices,
in which the VAT amount payable and the tax rate and the percentage, based on
which the tax can be calculated are not included. 127 The invoice issued by an
individually exempt taxable person must contain reference to the relevant national legal
provision or the relevant provisions of the VAT Directive or any other unambiguous
reference to the fact that it is exempt from tax.128
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The exempt taxable person may also be exempted from the obligation to issue an invoice
in accordance with the general rules and shall be subject to the obligation to issue a receipt
in accordance with the general rules.
Any taxable person who opted to cash accounting 129 must indicate the words
“pénzforgalmi elszámolás” (“cash accounting”) in each invoice that is issued for any
supply of goods and services (within the domestic territory) during the cash accounting
period and are subject to cash accounting. 130 If cash accounting does not apply to any
supply of goods and services of the taxable person opting for cash accounting (e.g. tax
exempt intra-Community supply of goods, transaction falling within the scope of Section
10 a) of the VAT Act, transaction subject to reverse charge procedure), the words
“pénzforgalmi elszámolás” (“cash accounting”) do not need to be indicated in the invoice,
even if the transaction is performed during the tax accounting period.
Any taxable person who applies the provisions of Chapter XIV of the VAT Act to his
agricultural activities must issue an invoice or a receipt according to the general rules
of the VAT Act.
The taxable person is exempted from the obligation to issue an invoice
- for any transaction based on which he is entitled to flat rate compensation131 and
- has one copy of the certificate in proof of purchase, issued by the person to whom the
goods or service is supplied.132
However, a taxable person is not exempted from the obligation to issue an invoice
even with regard to any transaction based on which he can claim flat rate
compensation, if the resident taxable person, obliged to pay the flat rate compensation
- does not issue a certificate in proof of purchase to the taxable person or
- when the flat rate compensation is payable by a taxable person established in a third
country or in another Member State of the Community.133
A taxable person engaged in agricultural activities under a special legal status must issue
an invoice for his transactions eligible for flat rate compensation in which instead of the
tax base the flat rate compensation base, instead of the tax rate the flat rate compensation
rate and instead of the tax amount payable the flat rate compensation payable are
indicated.134
products or services are supplied is a taxable person other than a taxable person engaged in agricultural
activities with a special status.
132 Section 202(2) a) of the VAT Act.
133 Section 202(2) b) of the VAT Act.
134 Section 202(2) b) of the VAT Act.
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Any taxable person established in the domestic territory with a non-special status,
receiving goods or services from a taxable person engaged in agricultural activities
under a special status as described in Annex 7 of the VAT Act and those products and
services were produced by that taxable person, shall issue a certificate in proof of
purchase. Based on the issued certificate in proof of purchase, the taxable person engaged
in agricultural activities under a special legal status will be exempted from the obligation
to issue an invoice.135
The certificate in proof of purchase must contain the following information:
- the date of issue of the certificate in proof of purchase;
- a sequential number, which uniquely identifies the certificate in proof of purchase;
- the name, address and tax number of the supplier of the goods and/or services, and of
the customer to whom the goods and/or services are supplied;
- the description of the goods supplied, and the relevant tariff heading used in the VAT
Act, where applicable, the quantity of the goods and the description of the services
rendered, furthermore, the extent and nature of the services rendered, if it can be
expressed in some unit of measurement;
- the date of supply, if it differs from the date of issue of the certificate in proof of
purchase;
- the flat-rate compensation base, the unit price of the goods supplied, exclusive of flat-
rate compensation, and the unit price of the services supplied, exclusive of flat-rate
compensation, if it can be expressed in some unit of measurement, any price discount,
provided that it is not included in the unit price;
- the rate of flat-rate compensation applied;
- the amount of flat-rate compensation;
- the signature of the supplier of the goods and/or services, and of the customer to
whom the goods and/or services are supplied.136
The obligation to issue a certificate in proof of purchase may be fulfilled only by the person
to whom the product or service is supplied. An aggregate certificate in proof of purchase
or a certificate in proof of purchase with simplified content cannot be issued for such a
transaction.137 Regarding any issue concerning the certificate in proof of purchase, not
regulated in Chapter XIV of the VAT Act, the provisions of the VAT Act pertaining to
invoicing must be applied.138
Invoices issued pursuant to of Chapter XVI sub-chapter 2 of the VAT Act for the supply of
goods (or payment on account to be included in the consideration for the goods) falling
within the scope of a special taxation mode the VAT amount payable, the tax rate and
the percentage indicating the tax content cannot be indicated.139 The invoices issued
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for such transactions the words “különbözet szerinti szabályozás - használt cikkek”
(“margin scheme - second-hand goods”); “különbözet szerinti szabályozás -
műalkotások” (“margin scheme - works of art”) or “különbözet szerinti szabályozás -
gyűjteménydarabok és régiségek” (“margin scheme - collector’s items and antiques”)
should be indicated, respectively.140