The National Tax and Customs Administration of Hungary (NAV) has released its 2025 audit plan, highlighting significant progress in targeted, risk-based tax inspections. This year, the emphasis remains on digital data analysis, taxpayer segmentation based on behavior, and the introduction of new types of inspections.

New Tool: Data Reconciliation Procedure

The most important novelty is the introduction of a new type of administrative measure called the data reconciliation procedure. This process does not qualify as a classical audit. Its aim is simply to notify the taxpayer about discrepancies detected by NAV—such as differences between tax returns, online invoice data, or cash register reports—and give them the opportunity to voluntarily correct the issues in a compliant manner. Ignoring the notification may result in a fine of up to HUF 300,000 and potentially trigger a full audit.

Priority on Large Taxpayers and Related Parties

Large taxpayers remain a key focus group, especially in relation to the correct application of corporate income tax base adjustments, tax benefits, and transfer pricing practices. NAV will also continue to scrutinize transactions between related companies, particularly in light of tightening OECD guidelines and local transfer pricing documentation requirements.

E-commerce, Vending Machines, Trust Structures in Focus

The 2025 audit plan targets several new sectors:

• E-commerce platforms (domestic and international): Authorities will pay close attention to sellers’ registration, data reporting, and VAT compliance.

• Unmanned vending machines: These are considered high-risk due to potential data loss, leading NAV to launch targeted on-site inspections.

• Trust structures: NAV will investigate the true intent behind these arrangements, focusing on potential misuse for asset protection or tax minimization.

Continued Focus on Risky Taxpayer Behavior

NAV will keep a close eye on taxpayers who:

• Have been operating for years using shareholder loans as their main source of financing;

• Regularly defer VAT payments;

• Report exceptionally high turnover in their first year of operation;

• Are involved in used vehicle trading, construction, or fruit and vegetable wholesale.

Cooperation with Other Authorities Against the Shadow Economy

NAV often collaborates with the Labour Authority during inspections in the construction and hospitality sectors, primarily to combat undeclared employment. Additionally, the agency works with the Police and the National Bureau of Investigation to dismantle VAT fraud schemes.

The number of targeted inspections is expected to increase further, with the tax authority deploying all available tools to ensure compliance. Those with questions about transfer pricing documentation, VAT returns, or how to address risk indicators are advised to consult with a tax expert.