What is at risk if you miss the Hungarian VAT registration?
If your company is established elsewhere in the EU but does business in Hungary, chances are you’ll hit situations where a Hungarian VAT registration is mandatory - even without a local legal entity or office. Skipping that registration (and the resulting VAT returns and payments) is not a harmless administrative gap; it creates real tax, penalty, and audit risk. This post lays out when registration is required, why OSS or “intra-Community” rules won’t save you in some common scenarios, and how a local advisor can reduce risk and friction with the Hungarian Tax Authority (NAV).
What’s the baseline? Registration comes before activity
Hungarian rules require taxpayers to fulfil their registration obligation prior to starting business activity in Hungary. For non-established companies, that typically means filing form T201 and obtaining a Hungarian VAT number before your first taxable supply in Hungary. And after that, you should apply the local rules for invoicing, tax return submission and tax payment.
“Can’t we just use OSS or treat it as an intra-Community transaction?”
Often - but not always. Three frequent counter-examples where OSS or “intra-Community” treatment doesn’t work and a Hungarian VAT ID is required:
1. Domestic sales from stock located in Hungary If you hold inventory in a Hungarian warehouse (own or 3PL) and sell to customers in Hungary, those are domestic supplies—outside the scope of OSS (except certain marketplace “deemed-supplier” cases). You must charge Hungarian VAT from a Hungarian VAT number and file local returns.
2. Goods supplied with installation/assembly in Hungary Under EU rules, the place of supply for goods installed/assembled by the supplier is where the installation happens. If you install machinery in Hungary, the place of supply is in Hungary, thus B2C relations requiring a Hungarian VAT registration and local invoicing. OSS doesn’t apply because this is not a cross-border B2C distance sale.
3. Dispatches from Hungary to other EU countries (your own stock moving or sales that ship from HU) When goods leave Hungary to another Member State, you’re making intra-Community supplies from Hungary, which must be reported on Hungarian EC Sales Lists (A60) and, where conditions are met, can be tax-exempt. You can’t report those from another country’s VAT number.
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What risks do you run if you don’t register (but should)?
Default penalties for non-compliance. NAV explicitly lists the default penalty as the typical consequence for failing or delaying registration.
Recent changes align the general default penalty cap for companies at HUF 1 million, while specific breaches of invoicing/receipt/document rules can be penalised up to HUF 2 million per case.
Tax shortfall penalties. If a tax audit finds underpaid VAT, NAV can impose a tax penalty of 50% of the shortfall—or 200% in aggravated cases (e.g., concealment, false records).
Late-payment interest. Interest may accrue daily at the Hungarian central bank (MNB) base rate + 5 percentage points (calculated as 1/365th per day) for taxes not paid by the deadline. The surcharge is generally calculated from the original due date until the date of the audit minutes (but for a maximum of 3 years).
Failure of reporting liabilities. Where you should have been registered, expect NAV to look for the VAT return(s), EC Sales and Purchase Lists (A60) for intra-EU movements, and – depending on flows – Intrastat. Missing or incorrect statements can trigger further penalties (up to HUF 1 million in tax cases and up to HUF 2 million in statistical cases).
Business risks. Due to invalid or incorrect invoices, customers may face VAT deduction and cost settlement problems. To avoid this, partners explicitly require correct Hungarian invoicing and even proof of tax compliance. And when faced with a NAV sanction, they can take legal action against the partner and claim compensation. Legal operation is therefore also a matter of business security.
Prevent costly tax penalties – contact our Hungarian VAT expert before commencing business in Hungary.
Why you may need more than just a VAT registration?
Permanent establishment (PE) risk. If your operations in Hungary show a sufficient degree of permanence and human/technical resources to supply or receive services, produce goods or trade with them, you may create a VAT fixed establishment in Hungary - changing place-of-supply and compliance obligations.
Local Business Tax (LBT) and Corporate Income Tax (CIT). Beyond VAT, performing business in Hungary for a permanent or prolonged period can trigger a permanent establishment from the LBT and even the CIT point of view. LBT (up to 2% of the adjusted net revenue) and CIT (9% of the adjusted profit before tax) exposure and the related registration could cause an extra compliance cost for a Hungarian business activity. Thus, a feasibility check before scaling the activity is essential.
How to reduce risk (and headaches)?
1. Pre-activity review. Have a local expert test your planned flows (stock, installation, subcontracting, event activity) against place-of-supply and PE rules, and check for HIPA and CIT exposure.
2. Register on time. Where needed, obtain your Hungarian VAT ID before first supply; build the compliance calendar (VAT returns, EC Sales and Purchase Lists, Intrastat, etc.).
3. Invoice correctly. Use Hungarian VAT and local invoicing content rules, further the Online Invoice reporting for domestic supplies. Breaches of invoice/receipt obligations could be levied with a default penalty separately.
4. Keep documentation and evidence. Tax-exempt intra-Community supplies require proof of transport and correct EC Sales Lists; NAV expects robust files.
5. Keep monitoring. Follow thresholds (OSS, , tax return frequency, Intrastat), changes in contracts and logistics; these can generate a registration obligation in one step.
Need help? Our bilingual experts are here to help.
Need help? A bilingual local team makes a real difference
To ensure smooth communication with NAV and to mitigate risks, foreign companies should hire an expert who speaks both Hungarian and English and is familiar with local regulations. This is especially true for:
- Processing the registration and obtaining a Hungarian tax number,
- Preparing and submitting regular VAT returns, EC Sales and Purchase Lists (A60) and – if necessary – Intrastat reports,
- Communicating with NAV, commenting on the tax audit minutes and preparing legal remedies,
- Continuous compliance monitoring of the activity and ad-hoc tax advice.
Our team supports end-to-end Hungarian VAT compliance for non-resident businesses—advising on whether you must register, securing the VAT number, preparing returns, EC Sales and Purchase Lists, and handling NAV correspondence and audits.
Final takeaway
If you sell from Hungarian stock, install in Hungary in B2C, or dispatch from Hungary, you are very likely in local VAT registration territory. OSS won’t cover those domestic or installation scenarios, and “intra-Community” labels only apply when legal conditions are met and properly reported from Hungary. Getting this right up front—with local, bilingual expertise—is far cheaper than navigating penalties later.
This blog post was written byJózsef Vizer, Lead Tax Advisor at ICT Business Advisory Zrt.
This article provides general guidance only and is not legal or tax advice. For tailored advice on your specific supply chain and contracts, please reach out to our Hungarian VAT team.
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