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Pre-audit services

Data export and online invoice data reporting

PwC’s latest pre-audit services enable you to prepare for a Tax Authority audit, minimizing the risks of sanctions.

Hungarian taxpayers are obliged* to meet – among others – two important obligations related to their invoicing systems.

Invoicing systems are statutorily required** to have a data export function. This data export function generates a data export file about the invoices issued by the taxpayer for a certain series range or for a given period. As per the second obligation, from 1 July 2018 the invoicing systems have to be able to report the invoice data online as well (Section 13/A of the Invoicing Decree). 

If there is an audit, the data export file must be provided upon request of the National Tax and Customs Authority (“Tax authority”). The data export file generated by the data export function must be in XML format, with a prescribed data content and in a compulsory structure determined by Annex I. and Annex II. or by Section 13/A of the Invoicing Decree. 

Due to introduction of the online reporting obligation, taxpayers have to supply data online regarding sales invoices issued by an invoicing system to Hungarian taxable persons, if the VAT content of those invoices equals or exceeds HUF 100,000. The required invoice data has to be provided to the Tax authority’s system on a real time basis, immediately upon issuance, electronically, in a specified XML file format.

Based on our experience regarding the recent practices of the Tax Authority, during a tax audit the Tax Authority in every case requires the taxpayers to provide the data export file for the period under audit. Based on the data export file, the Tax Authority checks the discrepancies between the two obligations – i.e. between the data of the invoices reported through the online reporting system and the data included in the data export file – and reveals the differences. Consequently, it is advisable to reconcile the data of the data export file and the online reported invoice data before a possible tax audit – in order to test the data content consistency in the two obligations – in order to avoid risks and penalties arising from the possible deviations.

During the pre-audit services we inspect the following in particular:

  • whether the invoices issued from the invoicing system have actually been reported to the Tax Authority’s system on an invoice number level;

  • whether there is any time difference between the issue date and report date of the invoice;

  • amongst other data, we check whether the net amount and VAT amount correspond between the data export and the online reported data.

We provide a detailed report to our clients after the pre-audit. Depending on the results of the pre-audit, we will suggest any corrections or modification, if necessary.

The above pre-audit service does not require any time or labour from our client’s side, as it is fully performed by PwC with our self-developed application, after the required data is made available.

Based on our experience, many company’s invoicing systems still do not have the required data export functionality. Our experts are available to assist you in acquiring such data export capabilities.

*According to Decree No. 23/2014. (VI. 30.) NGM on the tax administration identification of invoices and receipts, and the verification of electronically stored invoices by the tax authority (“Invoicing Decree”)

** Section 11/A of the Invoicing Decree, introduced on 1 January 2016 


Deák László

Deák László

Cégtárs, PwC Hungary

Farkas Gábor

Farkas Gábor

Cégtárs, PwC Hungary

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