The Hungarian Tax Authority’s 2025 Audit Plan: New Formats, Digital Tools, and Focus Areas
The Hungarian National Tax and Customs Authority (NAV) has released its 2025 audit plan, building on its risk-based approach with expanded use of data analytics and AI. This year’s framework introduces a new data reconciliation procedure while continuing to refine existing audit types, including supportive procedures, compliance reviews, and standard tax and customs audits.
NAV maintains a dual strategy: it aims to support cooperative taxpayers while stepping up enforcement against suspected fraud.
Focus on Key Taxpayers and Risk Areas
As in previous years, large taxpayers and key contributors to the national economy remain central to NAV’s audit focus. In particular:
Tax incentive use, corporate income tax adjustments, rehabilitation contributions, and exempt income reporting will be reviewed.
Related party transactions will undergo increased transfer pricing scrutiny.
Targeted Sectors and New Inclusions
Several sectors remain under active monitoring, including:
Businesses with long-term reliance on member loans
Companies with abnormal VAT deduction patterns
Firms with rapid turnover growth in their first year
Used car dealers, IT product traders, content providers, construction companies, and more.
In 2025, new groups enter the audit radar, particularly:
Operators and vendors on domestic and foreign e-commerce platforms
Entities involved in product import activities
Digital Tools and the Rise of AI Audits
NAV’s Artificial Intelligence Task Force, launched in 2024, will further enhance audit selection by analysing:
Discrepancies between online cash register data and VAT returns
Inconsistencies between e-invoice records and tax filings
Signals from the EKAER transport data system and the National Tourism Data Supply Centre
A notable innovation in 2025 is the introduction of “municipality control”, comparing turnover across businesses in the same region and industry to detect underperforming or suspicious entities.
NAV will also begin auditing unmanned vending machines where data reporting violations are likely.
New Tool: Data Reconciliation Procedure
A significant procedural development is the new data reconciliation mechanism. When NAV detects inconsistencies between filed tax returns and its internal data, taxpayers will be notified and invited to correct the issue voluntarily.
Failure to respond may trigger a fine of HUF 300,000 and lead to a formal tax audit.
Enhanced Oversight of Trusts and Employment Schemes
Following a sharp rise in the use of trust structures, NAV will now investigate:
Legal compliance
Risk of asset diversion via trust settlements
Meanwhile, taxpayers using simplified employment schemes but failing to report contributions or employee data may also face scrutiny.
Stronger Enforcement Measures and Cooperation
NAV will intensify its use of tools to fight tax fraud, including:
Risk segmentation and international data analysis
Asset freezes, enforcement actions, and criminal proceedings, where appropriate
The agency will also strengthen cooperation with:
The Labour Inspectorate (for joint inspections, especially in construction and hospitality)
The police and the National Bureau of Investigation, particularly for detecting VAT fraud rings
Spotlight on Non-Cooperative Jurisdictions
Aligned with EU and OECD guidance, NAV will audit entities conducting business with non-cooperative tax jurisdictions, especially where profits originate from these regions.
