Transfer Pricing Audits in 2026: What will NAV focus on and how significant is the risk?
Transfer pricing documentation received heightened attention from the National Tax and Customs Administration of Hungary (NAV) over the past year, and this trend is expected to intensify further in 2026. The 2026 audit plan clearly indicates that the tax authority is no longer merely examining the formal existence of documentation but is also analyzing the profitability, trends, and potential discrepancies of intra-group transactions using automated data comparison systems.
Hogyan választja ki a NAV az ellenőrizendő társaságokat?
NAV identifies companies for review on the basis of transfer pricing data reporting, international exchange of information, country-by-country reports and other risk indicators, focusing on those where there is a higher likelihood of a deviation from the arm’s length price. As a result, even before launching an audit, the tax authority may already form a view of profitability trends, transaction values and the methodologies applied in controlled transactions, even before requesting the local file.
Based on the 2026 audit focus, businesses whose related-party transactions involve intangibles, intra-group loans or other financial transactions should particularly expect a tax audit. Increased attention may also be paid to companies operating as routine manufacturers, distributors or agents that are loss-making or generate only exceptionally low profits.
NAV also expressly highlights transactions classified as high-risk on the basis of transfer pricing data reporting. In addition, the audit plan identifies specific sectors as focus areas: companies engaged in related-party transactions in the pharmaceutical, food, construction, automotive, IT and software development sectors may expect increased attention.
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Transfer pricing adjustment
It is important to note that transfer pricing risk is not the same as documentation risk. If related parties apply consideration that differs from the arm’s length price, the taxpayer’s profit before tax must be adjusted by the difference between the arm’s length price and the consideration actually applied. The essence of the rule is that the tax base should ultimately reflect the result that would have arisen had the parties entered into their transactions on arm’s length terms.
An upward adjustment is required where, as a result of the consideration applied, the taxpayer’s profit is lower than it would have been under arm’s length pricing. A downward adjustment applies where, due to the consideration used, the taxpayer’s profit before tax is higher than would have been justified under arm’s length pricing.
It is also important to emphasise that the obligation to make an adjustment is not the same as the documentation or data reporting obligation. Accordingly, there may be cases where no separate transfer pricing documentation or data reporting is required for a transaction, yet a tax base adjustment is still necessary.
What transfer pricing risks does the Hungarian Tax Authority focus on in 2026?
Sanctions: tax penalty, late payment interest and default penalty
Sanctions may arise on several levels. If the required adjustment is not made, the audit may establish a tax deficiency, for which a tax penalty may also be imposed. The general rate of this is 50% of the tax deficiency. In addition, late payment interest is also charged on the tax deficiency, the daily rate of which can result in a significant amount over time.
The other significant category of sanctions relates to documentation obligations. Transfer pricing documentation and related data reporting are essential elements of audits. Due to seriously incorrect, incomplete, or missing documentation, a default penalty of up to HUF 5 million per document, or up to HUF 10 million in case of repeated violation, may be imposed.
Incorrect or incomplete fulfillment of transfer pricing data reporting can also pose a significant risk for businesses. NAV will pay particular attention in 2026 to taxpayers who fail to fulfill this obligation. Under general penalty rules, non-natural person taxpayers may face default penalties of up to HUF 1 million for incorrect, incomplete, or false data content, or for late or non-fulfillment.
The year 2026 is particularly important because a new regulatory environment has entered into force. The provisions of NGM Decree 45/2025. (XII. 23.) must, as a general rule, be applied first to transfer pricing records and data reporting related to tax years beginning in 2026. We have written in more detail about the new rules in our previous article .
What Is Worth Considering Now at the Close of the 2025 Business Year?
The close of the 2025 business year is a critical period for any company whose transactions with related entities exceed transfer pricing documentation thresholds.
Documentation prepared in time and accurate transfer pricing data reporting not only provide protection during NAV audits but also help prevent multi-million forint default penalties and the establishment of tax deficiencies.
If you have questions regarding your transfer pricing obligations or need assistance in preparing documentation, please contact us with confidence—our expert team will support you at every step.
Author: Emese Vass
Transfer price specialist
Request a free consultation for the preparation of your transfer pricing documentation!
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