What does NAV’s new audit plan tell companies? – EY analysis

According to the NAV’s inspection plan, the authority will continue to focus on investigations aimed at uncovering VAT fraud mechanisms and improving data accuracy this year. The tax office will analyze data from the Online Invoice, online and e-cash registers, EKÁER and the National Tourism Data Service Center (NTAK) in real time, in an integrated manner and with the support of artificial intelligence. In the case of VAT refunds classified as risky, data reconciliation procedures, supporting procedures and pre-allocation checks will continue to play a decisive role.

There are several new features in NAV’s plans

However, the 2026 plan also designates several new and more prominent audit directions. In response to the further growth of online purchases, NAV names the examination of the retail tax liability of e-commerce platforms as a separate goal, in addition to checking the rules of simplified VAT systems related to online sales. Due to the logistics chains related to sales, courier service providers and delivery companies also appear as separate risk target groups. But Internet content providers, event organization, advertising, marketing, media service and film production activities and their subcontractors can also expect special attention and inspection.

The inspection of the food chain supervision fee was already within the competence of the National Tax and Customs Administration last year, and in 2026 it will appear as an active, targeted inspection topic. In addition, the scope of inspections related to real estate transactions is expanding: in addition to real estate and land sales, real estate renovations, especially projects related to subsidized programs and energy saving systems, will also be subject to inspection.

Special attention will be paid to the largest taxpayers this year

As every year, the tax authority will focus on the top taxpayers with the highest tax performance, transactions between affiliated enterprises, transfer pricing and the fulfillment of transfer pricing data. In this area, the authority will designate those affected for inspection using a targeted, risk-based method. On the other hand, similarly to previous years, it will also apply a sector-specific approach, with particular attention to enterprises operating in the automotive, construction, chemical, and IT and software development sectors. The related pharmaceutical companies will certainly also be subject to control from a transfer pricing perspective.

On the customs side, NAV is further strengthening its previous control directions. The plan also includes the control of the EU Deforestation Regulation (EUDR), the intensification of pre-clearance customs value controls prior to the release of goods, and increased supervision of the turnover of small e-commerce packages.

The focus will also remain on the examination of taxes that qualify as “covered taxes” from the perspective of the global minimum tax; this year, the 2025 obligation will be subject to control. Special attention will be paid to, for example, the examination of the correctness of accounting settlements affecting after-tax profit.

“The significant increase in the number of audits related to transfer pricing is also confirmed by our own experience: the pricing of related transactions remains one of the most sensitive risk areas for the Tax Authority. While the global minimum tax appears to be practically a new type of tax, it is justified that the tax authority pays special attention to its application at an early stage of its introduction. The more prominent audit of e-commerce also fits well with market processes: the number of retail stores in Hungary decreased by about 6.4 percent in a single year, which clearly indicates the decline of traditional stores and the rise of online sales channels. In this environment, it is understandable that the Tax Authority is placing increasing focus on e-commerce business