The Hungarian Tax Authority (HTA) has published its audit plan for 2026. The plan reveals that HTA will use the data set available to it and will apply artificial intelligence to screen companies exhibiting indicators of potential risk. In 2026, taxpayers are expected to review and clarify the causes of discrepancies in tax returns and other data reporting, including those relating to online invoice reporting and VAT returns, with corrections required, where appropriate. Taxpayers demonstrating a cooperative approach can anticipate a supportive stance from the tax authority during data reconciliation procedures. By contrast, non-compliance may lead to the initiation of targeted tax and customs audits. In our newsletter, we show which areas will be the focus of HTA's investigation this year.
Personal income tax — what can individuals expect?
- Under the current audit plan, individuals earning income from abroad should anticipate increased audits from the tax authority.
- Information obtained through the international automatic exchange of information will be used to conduct compliance reviews. In the case of non-cooperative taxpayers or significant discrepancies, full tax audits may be initiated.
- A key focus will be on income and transactions connected to countries that are viewed as low-tax or “tax haven” jurisdictions.
- Drawing on its previous audit experience, the tax authority will also pay particular attention to tax incentives claimed against social tax in relation to vocational education and dual training programs.
Direct taxes of companies — what can companies expect?
- In 2026, the Tax Authority will place particular focus on corporate income tax allowances, including development tax allowances, allowance on investments aimed at improving energy efficiency, and the application of renovation tax benefits. It will also monitor development reserves established in 2024 and the reversal of reserves established in 2020.
- Based on the audit plan, the Tax Authority will further review the so-called covered taxes affecting the global minimum tax for 2025, namely corporate income tax, innovation contribution, and the income tax of energy suppliers. Particular attention will be paid to the utilization of tax loss carryforwards, as well as the accounting treatment of transactions affecting after-tax profit, tax liabilities, and deferred tax positions.
- Taxpayers engaged in event organization, advertising, marketing, media services and film production activities, as well as those with links to or deriving income from jurisdictions considered non-cooperative for tax purposes, may expect increased scrutiny.
- Based on its risk analysis and audit experience, the Tax Authority will prioritize the review of newly established companies, businesses whose operations have relied on shareholder loans over several years, and taxpayers providing or receiving so-called “acceptance” services.
- Based on data obtained through the automatic exchange of information, compliance reviews are also expected for taxpayers demonstrating a lack of cooperation with the tax authority and exhibiting significant tax discrepancies.
- For 2026, the Tax Authority may examine the fulfillment of tax obligations related to approved dividend distribution and companies with lack of equity due to permanent losses.
- The focus of Tax Authority investigation will be on taxpayers who have failed to file their retail tax returns, including online platforms.
Value Added Tax (VAT), customs and trade compliance — what can taxpayers expect?
- In 2026, key focus areas will continue to be the automotive industry, the agriculture and food industry, construction, and the service sector, among others. E-commerce platforms and businesses regularly engaged in product imports can also expect inspections to increase.
- As of 2025, responsibility for the food chain supervision fee has been transferred to the Tax Authority. Inspections in this area are also expected in 2026.
- The customs audit practice established during recent years will continue. Such practice generally includes examinations of the accuracy of declared customs values and the monitoring of the ever-increasing volume of e-commerce traffic.
- In 2026, increased scrutiny is expected in relation to goods subject to greenhouse gas regulations, the Carbon Border Adjustment Mechanism (CBAM), and the EU Deforestation Regulation (EUDR), with the involvement of the relevant authorities.
- In order to restrain VAT fraud, the 2026 audit plan indicates that companies that have been carrying forward VAT for several years, businesses engaged in high-risk activities, and taxpayers submitting “tax-minimizing” returns will remain a primary focus of HTA inspections. The Authority will continue to place particular emphasis on the consistency of VAT returns, Domestic Purchases Lists, online invoice data, and online cash register data.
Transfer Pricing — what can related parties expect?
- The Hungarian Tax Authority uses artificial intelligence-based analytical models and real-time data processing to identify high-risk companies, even at the time of invoice issuance.
- Targeted audits may be initiated based on country-by-country reports (CbCR), cross-border arrangements, transfer pricing data reporting, and international data exchange.
- There is a special audit focus on transactions involving intangible assets between related parties, as well as on the transfer pricing aspects of loans and other financial transactions.
- Manufacturing, agency, and distribution activities within corporate groups, as well as companies operating at a loss or with low profitability, are subject to increased scrutiny.
- Taxpayers who fail to comply with transfer pricing data reporting requirements will receive particular attention.
- Sector-specific focus areas include the automotive, construction, chemical, IT/software development, pharmaceutical, and food industries, which are especially in the spotlight for selection.
- Compliance with the conditions of advance pricing agreements (APAs) will also constitute a key audit focus.
What does this mean in practice?
The Hungarian Tax Authority’s operations are now fundamentally data-driven. For compliant taxpayers, the Authority promotes proper compliance through supportive procedures and data reconciliation, while deliberate non-compliance may trigger swift and targeted audits. Notably, transfer pricing is anticipated to remain a priority area, with audit activity in 2026 expected to exceed 2025 levels.
How can we help?
If you have any questions regarding the HTA’s audit focus areas for 2026, or if you need assistance in preparing for potential audits, please feel free to contact us.
