Hungary’s National Tax and Customs Administration (NAV) has released its audit strategy for the 2024 calendar year, highlighting transfer pricing as its key area of focus among other sectors. The new transfer pricing reporting obligation introduced in the last tax year, alongside the initial data submissions will be used to evaluate risk and for selection of audits in 2024.
The audit plan outlines transfer pricing concerning the following areas:
- Audits of related entities within the automotive sector;
- Assessment of compliance regarding the terms of advance pricing agreements (APAs) and the reporting of transfer pricing information;
- Specialized audits focusing on transfer pricing within pharmaceutical companies;
- Audits of transactions involving intangible assets between affiliated parties.
- Verification of country-by-country (CbC) reports and evaluating transactions deemed risky due to cross-border arrangements;
- Audits of loans or other financial transactions among related entities;
- Transfer pricing audits of taxpayers reporting losses or low profitability involved in intra-group manufacturing activities.
