Hungary’s National Tax and Customs Administration (NAV) has published its audit plan for 2025 on 11 March 2025, outlining priorities for tax, customs and law enforcement controls. The plan focuses on securing budget revenues through measures aimed at preventing and addressing non-compliance while maintaining a service-oriented role.

NAV will use data analysis and risk assessment methods, incorporating data science techniques to identify areas for audit. Depending on the level of risk and taxpayer compliance, NAV will apply different audit procedures, including data reconciliation and full-scale tax and customs audits.

Based on discrepancies between tax returns and control data available to the NAV the following taxpayer groups can expect increased scrutiny to enhance tax compliance:

  • Companies operating for years based on member loans.
  • Those continuously carrying forward previously generated deductible VAT.
  • Taxpayers consistently submitting zero-value tax returns but showing sales activity according to control data (e.g., online invoices, detailed partner VAT data, online cash registers).
  • Newly established businesses and those with personnel changes, especially those reporting a high number and/or high-value invoices in the Online Invoice system.
  • Businesses showing a sudden surge in turnover within a year of establishment.
  • Entities failing to submit VAT returns, declaring zero VAT liability, or not completing summary reports, yet engaging in activities based on control data and showing VAT control discrepancies, including those resuming operations after a dormant period.
  • Taxpayers with discrepancies between VAT returns, summary reports, and online invoice data, as well as those failing to submit VAT returns.
  • Entities registered at virtual office providers without declared premises or employees, and businesses sharing the same registered address.
  • Companies owned by individuals with a risky tax history, including those previously associated with deregistered or unreachable businesses.
  • Employers with a large workforce who, according to online invoice data, do not issue invoices.
  • High-revenue businesses operating without employees, minimising tax liability despite increasing turnover.
  • Businesses where the number of employees does not align with the number of premises (e.g., mixed grocery stores, beverage services, confectioneries, and restaurants).

In 2025, NAV will pay special attention to the following sectors and activities:

  • Businesses engaged in (used) vehicle and vehicle parts trade, vehicle repair services, and those selling tyres and rims.
  • Companies providing personal and property security services, building operation and maintenance, cleaning services, and temporary staffing.
  • Traders of computer and telecommunication products.
  • Sellers operating on websites and online platforms, including operators of domestic and international e-commerce platforms and those selling through them.
  • Online content providers.
  • Retailers and wholesalers of textiles.
  • Fruit and vegetable traders.
  • Taxpayers involved in the trade and large-scale procurement of food and agricultural products (e.g., sugar, cooking oil, cheese, coffee, chocolate, flour, mineral water, soft drinks, poppy seeds, walnuts, rice, soy, fertilisers, potatoes), as well as those engaged in food production.
  • Businesses operating in the construction sector and those trading in construction materials.
  • Event organisers and businesses involved in advertising, marketing, media services, and film production.
  • Tourism, hospitality, and accommodation service providers, as well as taxi drivers engaged in passenger transport.
  • Businesses engaged in regular product imports.
  • Sellers of Far Eastern products.
  • Taxpayers in the beauty industry (hairdressers, cosmetologists, nail technicians, pedicurists, style consultants) and those providing fitness services (personal trainers, masseurs). This also includes compliance with employment regulations for supporting staff, verification of the origin and documentation of sold dietary supplements, and the proper registration of revenues (daily tickets, monthly passes, and snack bar sales) through online cash registers.
  • Businesses engaged in activities subject to excise duty.

The plan highlights transfer pricing practices as a key focus, particularly within large corporate groups. NAV will examine transactions, routine business activities, financial operations, intangible assets, and compliance with transfer pricing documentation and reporting obligations.

Other areas of focus include large taxpayers, businesses in specific sectors, taxpayers identified as high-risk through targeted analysis, and those with financial links to tax non-cooperative jurisdictions.

The audit plan sets out the approach NAV will take in monitoring compliance and conducting audits in 2025.

Earlier, NAV released its audit strategy for the 2024 calendar year, highlighting transfer pricing as its key area of focus among other sectors.