The National Tax and Customs Authority of Hungary (NAV) has published its 2025 audit plan, which, similarly to the previous year, emphasizes a differentiated, risk-based approach. NAV continues to refine its audit selection process through the application of its vast data assets and artificial intelligence. Based on this data-driven methodology, the type of audit will be determined according to the taxpayer's compliance behavior. The types may include a newly introduced data reconciliation procedure, as well as previously utilized methods such as the supportive procedure, compliance review, or tax and customs audits.
The Hungarian Tax Authority remains committed to supporting cooperative taxpayers who strive to fulfill their tax obligations, while taking swift and rigorous action against fraudulent actors.
Key Contributors to the National Economy: Transfer Pricing and Tax Incentives
As in previous years, high-revenue taxpayers will remain a top priority for audits in 2025. Particular attention will be paid to the proper application of tax incentives, the correct determination of corporate income tax adjustments, compliance with rehabilitation contribution obligations, and the accounting of exempt income. Related party transactions will also be scrutinized in terms of applied transfer pricing.
Continuities and Innovations
The 2025 audit plan incorporates many elements of continuity. Tax audits can be expected for companies that have operated for years financed through member loans, businesses consistently rolling over deductible VAT, companies showing significant turnover growth within the first year of operation, as well as used car dealers, security service providers, traders in IT and telecommunications products, online content providers, fruit and vegetable sellers, and construction businesses.
A notable novelty in 2025 is the inclusion of both domestic and foreign e-commerce platform operators and vendors using these platforms, along with those engaged in product import activities.
Advancement in Digitalization
Following the establishment of the Artificial Intelligence Task Force in 2024, which was designed to exploit the potential of the Hungarian Tax Authority’s extensive data assets, this group has now been tasked with further enhancing audit selection processes.
In 2025, the Hungarian Tax Authority will continue to monitor discrepancies between data received from online cash registers and VAT returns, track the movement of goods based on data from the EKAER system, and analyze the consistency between online invoice data and tax returns—also utilizing data from the National Tourism Data Supply Centre.
A new level in the digital environment will be achieved through the comparison of turnover data across enterprises within the same business activity and geographic region over arbitrary timeframes, a procedure referred to as “municipality control.” This will enable targeted audits of businesses with significantly below-average performance.
Moreover, the Hungarian Tax Authority will begin overseeing the operation of unmanned vending machines, launching audits at sites where there is a high risk of data reporting violations.
New Procedure – Data Reconciliation for Greater Accuracy
A major innovation in 2025 is the introduction of the so-called data reconciliation procedure. This legal instrument aims to resolve discrepancies detected by the Hungarian Tax Authority before initiating a standard tax audit or compliance review. If the Hungarian Tax Authority’s risk analysis systems detect inconsistencies between the submitted tax returns, data disclosures, and its own data, it will notify the taxpayer and offer an opportunity to resolve the issue voluntarily.
However, failing to respond may result in an automatic fine of HUF 300,000 and the initiation of a tax audit.
Increased Scrutiny on Trust Structures
The surge in the use of trust management arrangements in recent years has attracted the Hungarian Tax Authority’s attention. Entities involved in trust structures can expect audits focusing on potential circumvention of legal provisions and detecting or preventing the diversion of assets through asset settlements.
Simplified Employment Scheme, More Inspections
Although a simplified employment scheme is a common practice, it comes at a price. In 2025, taxpayers who regularly use simplified employment schemes but fail to report related contributions or exclude these employees from tax filings —can expect audits.
Enhanced Asset Protection and Recovery Measures
The Hungarian Tax Authority’s 2025 plan clearly indicates an intensified use of all available tools to detect and combat tax fraud. This includes risk analysis procedures that may draw on international data, followed by segmentation-based processes to determine the appropriate audit type. Where necessary, the Hungarian Tax Authority may impose asset freezes, initiate enforcement procedures, or launch criminal proceedings.
Partner Authorities Also on the Move
To better protect fiscal interests, the Hungarian Tax Authority will cooperate even more closely with partner authorities during audits. For instance, the Hungarian Tax Authority and the Labour Inspectorate will conduct joint surprise inspections at construction sites and hospitality venues to detect undeclared employment and unfulfilled tax obligations.
The Hungarian Tax Authority also seeks stronger cooperation with the police and the National Bureau of Investigation to dismantle organized VAT fraud networks.
Tax Havens Are Bad Business
In line with EU and OECD guidelines on combating tax avoidance, The Hungarian Tax Authority will audit taxpayers engaged in business with jurisdictions deemed non-cooperative for tax purposes, especially where profits are sourced from such countries.