The scope of Hungary’s real-time reporting has been extended. From 1 January 2021, reporting obligations will also include invoices issued for domestic B2C transactions in addition to invoices relating to intra-community supplies and exports. However, the Ministry of Finance has granted a sanction-free three month grace period from 1 January to 31 March 2021 allowing businesses more time to comply with these new reporting obligations. This will also help with the transition from the current v2.0 XSD real-time reporting to the latest v3.0 XSD, which will be mandatory from 1 April 2021. For now, it’s uncertain if there will be a requirement to retroactively report the transactions not declared during the grace period.
Impact self-billing: Where a non-EU company (including UK companies post-Brexit) acquires goods or services from a Hungarian supplier and the parties apply self-billing in connection with these transactions, a real-time reporting obligation will arise for the non-EU company. In addition, joint and several liability will apply under any self-billing agreement, meaning that anyone entering into such arrangements with vendors in Hungary needs to be aware of these new rules.