NAV Publishes 2025 Audit Plan: New Procedures and Expanded Audit Scope
NAV Publishes 2025 Audit Plan: New Procedures and Expanded Audit Scope
On March 11, the National Tax and Customs Administration (NAV) published its 2025 audit plan, which details its specific directions and methods. As we have seen in recent years, the tax authority increasingly relies on artificial intelligence to enhance risk assessment. By utilizing AI and effectively analyzing the vast amount of data from tax reports, particularly from the NAV Online invoice system, the authority can precisely identify high-risk taxpayers and detect activities that pose a risk of tax fraud. The NAV has declared its intention to apply a differentiated regulatory approach.
Types of Procedures
Based on the available control data, NAV primarily considers a taxpayer's tax risk level and compliance behavior when selecting the type of procedure. In 2025, businesses may encounter the following audit forms:
Regardless of their classification, taxpayers in 2025 will likely encounter the newly introduced data reconciliation procedure. This process aims to detect discrepancies between control data available to the tax authority and the data reported by businesses, allowing taxpayers to correct these inconsistencies. If a taxpayer fails to resolve these discrepancies or does not respond to the inquiry, they may face not only a penalty for non-compliance but also a compliance review or, in severe cases, a full tax audit. By complying with this request, taxpayers can avoid both potential penalties and the prospect of a tax audit.
Main Directions of 2025 Audits
Audits of High-Priority and High-Tax-Contributing Entities
One of NAV’s primary goals is to audit high-priority and high-tax-contributing entities, particularly those engaged in activities classified as risky based on their transfer pricing reports, loss-making operations, or low profitability.
Ongoing Monitoring of Discrepancies
Significant emphasis will continue to be placed on the ongoing monitoring of discrepancies between tax returns and the data available to NAV. The primary objective of this initiative is to enhance tax compliance, improve VAT fraud detection, and uncover and eliminate emerging fraud schemes promptly. The NAV is especially likely to scrutinize businesses that:
In 2025, the NAV will further expand its focus on high-risk industries, with increased scrutiny on the following sectors:
With assistance from the NAV’s Artificial Intelligence (AI) Task Force and real-time data analysis, the tax authority can now better understand taxpayers’ economic relationships and actual business activities. This allows NAV to detect budgetary fraud in real-time and take targeted action against identified tax evasion schemes.
Special attention will be given to discrepancies between data from online cash registers and VAT returns. Additionally, the tax authority will focus on information gathered from automated vending machines, the Electronic Public Road Trade Control System (eKÁER), the National Tourism Data Supply Center (NTAK), the “Glass Gate” Construction Industry Monitoring and Data Service System, as well as the OSS and IOSS systems. As a result, businesses should pay close attention not only to VAT returns but also to their compliance with associated data reporting obligations.
In 2025, targeted audits will also extend to customs representatives and trust managers. Indirect customs representatives must conduct partner audits before validating the assigned tax deduction rights of general and high-risk importers and report their findings. Failure to do so or any irregularities detected in these audits may serve as evidence in NAV’s enforcement actions.
Encouraging Voluntary Compliance
The NAV aims to promote voluntary compliance through supportive procedures. Taxpayers whose returns contain minor errors, which are not systematic or indicative of fraudulent intent, will encounter this process. However, taxpayers who neglect or incorrectly fulfill their tax obligations will face stricter enforcement in 2025, including immediate tax audits instead of prior warnings.
Planned Customs Audit Focus Areas
As with tax matters, customs audits will be primarily risk-based and targeted, though random inspections and action-oriented audits will still occur in 2025. The primary focus areas for customs audits include:
Krisztián Kövesdi, Brigitta Dr. Mucsi-Szabó
Types of Procedures
Based on the available control data, NAV primarily considers a taxpayer's tax risk level and compliance behavior when selecting the type of procedure. In 2025, businesses may encounter the following audit forms:
- Data reconciliation procedure (new procedure)
- Supportive procedure
- Compliance review
- Tax and customs audit
Regardless of their classification, taxpayers in 2025 will likely encounter the newly introduced data reconciliation procedure. This process aims to detect discrepancies between control data available to the tax authority and the data reported by businesses, allowing taxpayers to correct these inconsistencies. If a taxpayer fails to resolve these discrepancies or does not respond to the inquiry, they may face not only a penalty for non-compliance but also a compliance review or, in severe cases, a full tax audit. By complying with this request, taxpayers can avoid both potential penalties and the prospect of a tax audit.
Main Directions of 2025 Audits
Audits of High-Priority and High-Tax-Contributing Entities
One of NAV’s primary goals is to audit high-priority and high-tax-contributing entities, particularly those engaged in activities classified as risky based on their transfer pricing reports, loss-making operations, or low profitability.
Ongoing Monitoring of Discrepancies
Significant emphasis will continue to be placed on the ongoing monitoring of discrepancies between tax returns and the data available to NAV. The primary objective of this initiative is to enhance tax compliance, improve VAT fraud detection, and uncover and eliminate emerging fraud schemes promptly. The NAV is especially likely to scrutinize businesses that:
- Continually carry forward deductible VAT over multiple years,
- Submit zero VAT returns despite evidence of sales from control data,
- Are newly established with a high volume and/or high-value invoices and experience a rapid increase in revenue,
- Fail to submit VAT returns or report figures that do not match the NAV Online system data.
In 2025, the NAV will further expand its focus on high-risk industries, with increased scrutiny on the following sectors:
- (Used) motor vehicle and auto parts trade
- Construction and building material trade
- Security services and labor leasing
- Fruit and vegetable trade
- Tourism, hospitality, and accommodation services
- Website sales, online content services, and event organization
- Other media services
- Domestic and international e-commerce platforms
- Import activities
- Trade of goods from the Far East
- Beauty and fitness services
- Excise-duty-related activities
With assistance from the NAV’s Artificial Intelligence (AI) Task Force and real-time data analysis, the tax authority can now better understand taxpayers’ economic relationships and actual business activities. This allows NAV to detect budgetary fraud in real-time and take targeted action against identified tax evasion schemes.
Special attention will be given to discrepancies between data from online cash registers and VAT returns. Additionally, the tax authority will focus on information gathered from automated vending machines, the Electronic Public Road Trade Control System (eKÁER), the National Tourism Data Supply Center (NTAK), the “Glass Gate” Construction Industry Monitoring and Data Service System, as well as the OSS and IOSS systems. As a result, businesses should pay close attention not only to VAT returns but also to their compliance with associated data reporting obligations.
In 2025, targeted audits will also extend to customs representatives and trust managers. Indirect customs representatives must conduct partner audits before validating the assigned tax deduction rights of general and high-risk importers and report their findings. Failure to do so or any irregularities detected in these audits may serve as evidence in NAV’s enforcement actions.
Encouraging Voluntary Compliance
The NAV aims to promote voluntary compliance through supportive procedures. Taxpayers whose returns contain minor errors, which are not systematic or indicative of fraudulent intent, will encounter this process. However, taxpayers who neglect or incorrectly fulfill their tax obligations will face stricter enforcement in 2025, including immediate tax audits instead of prior warnings.
Planned Customs Audit Focus Areas
As with tax matters, customs audits will be primarily risk-based and targeted, though random inspections and action-oriented audits will still occur in 2025. The primary focus areas for customs audits include:
- Dual-use goods imported from third countries
- Firearms and military products
- Environmental compliance, such as reducing fluorinated greenhouse gases
Krisztián Kövesdi, Brigitta Dr. Mucsi-Szabó