According to the 2026 tax inspection plan of the Hungarian tax authority, taxpayers selected for audit this year will be chosen even more through data‑driven processes, using artificial intelligence and relying heavily on real‑time information, compared to the previous year. Businesses that make mistakes but remain cooperative will continue to receive support from the tax authority, while repeated non‑compliance will trigger fast and firm action. Digitalisation changes will also affect on‑site inspections: the Hungarian tax authority will record findings in electronic minutes and send them to the affected taxpayers electronically.
Strengthening of transfer pricing audits
One of the most important areas of the 2026 tax inspection plan of the Hungarian tax authority is the review of pricing between related parties. Even compared to the already high number of inspections in 2025, a further increase is expected. The tax authority uses AI‑based analytical models and real‑time data processing to filter high‑risk companies, even as early as the moment an invoice is issued.
The audits will particularly target companies performing limited‑risk “routine” manufacturing, distribution or service activities, yet operating at a loss or with extremely low profitability.
Priority sectors of inspections in 2026:
- automotive industry
- construction industry
- chemical industry
- IT/software development
The Hungarian tax authority selects companies for audit based on sector‑specific risk analysis, so businesses operating in these sectors should review their transfer pricing documentation and applied pricing methods in time.
Key transfer pricing audit points:
- transactions involving intangible assets between related parties
- loans and other financial transactions
- transfer pricing data reporting
- compliance with the conditions of advance pricing agreements (APAs)
Targeted audits may also be launched based on country‑by‑country reports (CbCR), cross‑border structures, transfer pricing data reporting, and international data exchange.
Inspection of companies’ direct taxes
With regard to direct taxes of companies, the 2026 tax inspection plan of the Hungarian tax authority will prioritise the review of the following data:
- corporate tax incentives (e.g. development tax allowances, investments serving energy‑efficiency goals, etc.)
- development reserve allocated in 2024
- release of the tied-up reserve allocated in 2020
- covered taxes related to the global minimum tax (corporate tax, innovation contribution, income tax of energy suppliers)
- accounting treatment affecting after‑tax profit and tax liabilities
- loss carry forwards
Taxpayers expecting increased audits in the area of direct taxes:
- taxpayers engaged in event organisation, advertising, marketing, media services and film production
- taxpayers with connections to non‑cooperative jurisdictions and deriving profit from such countries
- newly established companiescompanies operating for years based on shareholder loans
- providers and users of registered seat services
Based on automatic international tax information exchange data, even non‑cooperative taxpayers with the largest tax discrepancies should expect compliance audits.
In addition, the Hungarian tax authority will continue to examine in 2026:
- fulfilment of tax obligations related to approved dividend payments
- companies with equity shortfalls due to long‑term losses
- taxpayers failing to file retail tax returns, including online platforms
International income of private individuals, social contribution tax allowances
The 2026 tax inspection plan of the Hungarian tax authority places even stronger emphasis on analysing financial account data obtained through international tax information exchange. As a baseline, supporting procedures or compliance inspections may be launched, while non‑cooperative taxpayers with significant discrepancies may face tax audits.
The Hungarian tax authority receives more information on foreign bank accounts, investments and other financial assets, enabling targeted audits of private individuals earning income from foreign sources.
Audits may also extend to capital market transactions and income from crypto asset transactions.
Based on previous audit experience, tax allowances relating to vocational education and dual training (claimed from the social contribution tax) will also be in the spotlight.
Audit of climate protection regulations
Owing to the EU’s green economy regulations, an increasing number of environmental requirements affect businesses. Accordingly, Hungarian customs audits will place greater focus on goods falling under the CBAM obligations.
Other high‑risk areas
According to the 2026 tax inspection plan of the Hungarian tax authority, the following high‑risk areas will remain in the focus of audits:
- automotive industry
- agriculture
- food industry
- construction industry
- service sector
- e‑commerce platforms
- businesses engaged in regular product imports
In 2026, the tax audits may also begin regarding the food chain inspection fee.
The customs inspection practices characteristic of previous years will continue. These typically include audits of customs value accuracy and supervision of the continuously growing e‑commerce traffic.
To combat VAT fraud, the 2026 tax inspection plan of the Hungarian tax authority will again focus on:
- companies carrying forward their VAT balances for multiple years
- businesses performing high‑risk activities
- taxpayers submitting “tax‑minimising” VAT returns
The tax authority will continue to closely monitor the consistency and discrepancies between VAT returns, recapitulative statements, online invoice data and online cash register information.
The tax authority will take an even stricter approach to undeclared (“black”) employment, which will lead to more frequent on‑site inspections. During these inspections, the tax authority will record findings using its digital procedural application (HEDI), making on‑site audits paperless and reducing administrative burden.
Although the goal of the Hungarian tax authority remains to assist compliant but occasionally mistaken businesses primarily through supporting or compliance procedures, the increasingly targeted and data‑driven audits planned for 2026 carry significant risk for anyone failing to meet statutory obligations. Businesses in Hungary should therefore review their internal processes now and, if needed, engage an expert to ensure that they face the 2026 tax inspections prepared, conscious and compliant. Whether during the audit or in subsequent legal remedy procedures, you can rely on the tax experts of WTS Klient Hungary.
This article provides general information and does not constitute advice.
