During invoicing, it is not uncommon for subsequently identified facts or administrative errors to make the modification of an already issued invoice necessary. In such cases, Hungarian VAT legislation allows the issuance of a document qualifying as an invoice, which modifies or corrects the data content of the original invoice. These documents – together with the original invoice – constitute the complete and valid documentation of the transaction.
Obligation to issue an invoice
The taxable person is required – unless the Hungarian VAT Act provides otherwise – to issue an invoice for the supply of goods or services as defined in the relevant sections of the Act, provided that the recipient is another person or entity different from the taxable person.
An invoice is any document that meets the requirements set out in Chapter 10 of the Hungarian VAT Act. Our previous articles provide more detailed information on the mandatory data content of invoices and the rules on issuing invoices.
However, certain facts or circumstances may come to light only after the invoice has been issued, making its modification necessary. Administrative errors may also occur, requiring correction. If an error is detected in a received invoice, it does not always need to be returned: the correction may be performed by issuing a document qualifying as an invoice, a term defined in Hungarian VAT Act.
What is considered a document qualifying as an invoice?
A document qualifying as an invoice is any document other than the original invoice that meets the statutory requirements and clearly refers to the specific invoice while modifying its data content. It is essentially a collective term for documents that adjust an invoice. A document qualifying as an invoice may be a cancellation invoice (reversal note) or a modifying invoice (correcting invoice with negative or positive amount, or a correcting invoice which does not affect the amount), provided that it meets the legal requirements.
The original invoice and the modifying document qualifying as an invoice are jointly valid and together form the documentation of the transaction.
Another accepted method is the so‑called two‑step modification, in which a cancellation invoice and a new invoice with correct data content are issued. In this case, both the cancellation invoice and the new invoice must refer to the original invoice; the three documents together constitute the valid documentation of the transaction. However, this method is not recommended when the tax base and/or VAT amount change, as it is more difficult to ensure correct electronic data reporting (i.e., Hungary’s online invoice reporting) and compliance in the VAT return.
It is also accepted practice that a supplier modifies the data content of multiple invoices with a single document qualifying as an invoice. In such cases, the document must include:
- references to all invoices whose data it modifies,
- the specific data elements of each invoice affected by the modification,
- the nature of the modification, and
- its numerical impact, if any.
All of these details must be presented clearly and transparently for every modified invoice. It is important to note that this solution can only be used for modifications affecting the tax base and/or VAT amount if all affected invoices must be reflected in the same VAT return period. In practice, this method may be difficult to apply, as not all invoicing systems are capable of generating such documents or ensuring compliant electronic reporting. Therefore, it must be applied with due caution.
When do we issue a document qualifying as an invoice?
A document qualifying as an invoice is required, among others, in the following cases:
If the originally issued invoice contains:
- an incorrect tax base or VAT amount,
- an incorrect VAT rate,
- an advance payment exceeding the total amount of the final invoice,
- a misspelled product or service description,
- an incorrect performance date,
- an incorrect buyer name, address, or tax number,
- or any missing supplementary data.
What requirements apply to such a modifying document?
The minimum data content of such a document is the following:
- the date of issuance,
- a unique serial number enabling unambiguous identification,
- a reference to the invoice whose data the document modifies,
- the specific invoice data being modified, as well as the nature of the modification and its numerical impact, if any.
The Hungarian VAT Act specifies only the minimum data content; any additional information considered relevant by the issuer may also be included.
Furthermore, the provisions applicable to invoices must also be applied to these documents. Therefore, from the date of issuance until the end of the statutory retention period, the following must be ensured:
- authenticity of origin,
- integrity of content and readability,
- and suitability for tax administration identification.
This also means that a document qualifying as an invoice may be issued using invoicing software or pre‑printed forms produced by a printing company.
Key points to keep in mind
Without aiming for completeness, the following aspects should be considered when issuing a modifying document :
- Electronic data reporting with the appropriate content is required even for documents qualifying as an invoice.
- It must be examined in which VAT return period the document should be included.
- Exchange rates may also cause issues; therefore, the exchange rate displayed by the invoicing software should always be verified.
- The performance date of the document qualifying as an invoice has to be the same as the performance date of the original invoice to be modified, unless the performance date itself is being modified.
- As a result of the invoice modification – taking into account both the original invoice and the modifying document – the tax base or VAT amount cannot become negative.
This article focuses primarily on invoices and documents qualifying as an invoice issued through invoicing software. It does not cover cases involving pre‑printed, manually completed invoices or documents qualifying as an invoice. Should you have any questions regarding the issuance of an invoice or a document qualifying as an invoice in Hungary, our highly experienced experts are happy to assist you.
This article provides general information and does not constitute advice.
