Online data disclosure to NAV – requirements, challenges and solutions
Taxpayers subject to mandatory online disclosure have to prepare for further changes concerning the scope of transactions affected, as well as the disclosed data. Compliance with the existing rules as well as future changes expected, poses considerable challenges for companies. Non-compliant data disclosure entails a significant risk of sanctions, as compliance of the quality of data remains in the focus of tax audits; also, the scope of disclosure is due to be extended in two phases.
Major milestones
Tax Authority information, autumn 2019
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Only 260 thousand of the registered 350 thousand taxpayers fulfil the data reporting.
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On average, 3 pieces of data out of ten are non-compliant.
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There are still numerous types of errors found in the reports: Deficient data reporting, Inappropriate management of modification invoices (references, signs), Inappropriate management of advance payments and final invoices, Inappropriate management of discounts.
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The immediate and automatic checks of the Tax Authority do not detect every error.
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Data reporting is often not immediate, automatic, and/or not performed within a closed system.
Deloitte’s approach
Deloitte has a complex solution package covering the entire set of data reporting criteria as an answer to the above challenges as follows.
The Tax Authority’s ’data export’
functionality
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Provision of all invoice data pertaining to all the sales transactions in the given period in the course of tax audits
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The report is not, or only incompletely available in numerous invoicing programmes
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Management of special transactions is often problematic
If you don’t have a solution yet:
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We undertake the individual conversion of invoice data into the format required by law for tax reviews
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We provide off-the-shelf software solutions (DataExport)
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We provide development advisory services in case of an implementation to an existing system
If you already have a solution, but you are uncertain about your compliance:
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We undertake to verify the compliance of the available solution as follows:
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verification of compliance on file level with the formal criteria
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verification of mandatory data content
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verification of content via random sampling of invoices
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full-scale verification of content based on preliminary interviews and the relevant invoices pertaining to the affected transactions
Real-time invoice data
reporting
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Immediate and automatic reporting of invoices of sales transactions with a VAT content of minimum HUF 100 000 issued for domestic tax subjects with the data content pursuant to the VAT Act
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Data reporting is often not immediate, disclosed data is incomplete or inappropriate
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High-quality reporting of invoice data is required from the first day of data disclosure
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Relatively fast mandatory changes
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Continuously expanding scope of transactions and data
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Special focus by the Tax Authority on tax audits on data quality compliance
If you don’t have a solution yet:
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We provide an off-the-shelf solution that can run both in a Deloitte and in a client environment (VATOnline), which can be flexibly connected with any invoicing/management system
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We provide development advisory services in case of implementation into existing systems
If you already have a solution, but you are uncertain about your compliance:
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We undertake to verify the compliance of the solution available as follows:
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verification of compliance with formal criteria on file level
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verification of mandatory data content
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verification of content via random sampling of invoices
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full-scale verification of content based on preliminary interviews and the relevant invoices pertaining to the affected transactions
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verification of reported data content on the Online Invoice platform
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verification of the immediateness and automaticity of the process
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full-scale verification of the data reporting process
Deloitte pre-audit
service
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Provision of data export files to the Tax Authority for a tax compliance audit regarding the real-time invoice data reporting
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Based on the above, the Tax Authority identifies the invoices subject to reporting obligation
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The Tax Authority compares the requested data export files with the reported data content from a volume as well as a content perspective
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In many cases, compliance with the online data reporting law meant a change of approach regarding previous invoicing practices; still, often only the technical requirements of the reporting were provided
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The quality of the reported data was often ignored compared to the compliance with the data reporting obligation
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Full-scale follow-up of data reporting is often not provided within the organisation
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The invoice data of the full scope of transactions drawn from the data export audit file may differ from the data content reported in the Online Invoice system in volume or in the scope of data reported
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Our service includes running an audit process similar to a tax audit, in the course of which we compare the invoices included in the data export XML file with the data reported to the Online Invoice System, and discovering system-level problems and risks based on this comparison
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We review the compliance of the data export file with the formal requirements
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We make recommendations and offer a solution for the mitigation and management of risks identified by us
