Where will NTA knock next?

At the beginning of every year, the National Tax and Customs Administration (NTA) publishes its audit plan concerning the main directions and principles of the tax audits for the given year. By summarizing the main objectives of this year’s audit plan published in March 2024, our newsletter aims to raise the attention of tax payers specifically affected by the planned audits or operating in high-risk areas, so that a possible investigation during the year would not be unexpected.

A key element of the 2024 audits will be the differentiated approach based on risk analysis, relying heavily on data collected through the NTA's IT systems (e.g. online cash register, EKAER). During the audits, NTA will support taxpayers who are cooperative and engage in lawful conduct. In their case, the main objective is to provide support aimed at the correction of errors, rather than to impose sanctions.  On the other hand, taxpayers who deliberately and seriously violate the tax laws can expect strong action. The NTA aims to adopt an even more differentiated approach, where the behavior of the taxpayer will strongly affect the type of the audits to be performed.

According to NTA's audit plan, special focus will be on event organizers, advertising, marketing and media service providers, and on those who earn income from cryptocurrency. In addition, taxpayers operating in the beauty industry and fitness services may also be in the focus of audits. Of course, sectors that have been subject to audits for a long time, such as the construction industry, personal and property protection, fruit and vegetable trade, and sales on websites and online marketplaces, will also continue to be in the focus of the investigations.

Investigating large taxpayers will remain an important duty of the NTA. In addition, the tax authority will closely examine the rights to apply tax allowances, as well as the method of determining the prices applied between related parties.

With the advancement of digitalization, transaction-based returns and data provisions are replacing traditional return methods. That is the reason why continuous data analysis, and the detection of system-based mistakes are essential. Thus, NTA will examine the data provisions more strictly, as the various risk analysis models can only operate on the basis of correct input data.

Important changes are also expected in the area of customs audits, which will focus on the challenges of e-commerce, in addition to the audits of tax and VAT payments on imported vehicles. Product safety of imported goods and the detection of counterfeit goods will remain the focus area of the audits.

Summarizing the above, the NTA audit plan focuses on a number of important areas, and it is important for taxpayers to be aware of the current rules. Legal compliance and cooperation are always important when dealing with the authorities.

If, on the basis of the above, you believe that based on its activities or transactions your company may be in the focus of the tax authority’s attention in the near future, performing a comprehensive tax audit or a detailed audit focusing on high-risk activities (areas) may worth considering.

This process enables the company's management to be aware of the risks and to decide on correcting bad practices and submitting self-revision regarding identified tax differences before the tax authority's audit begins. By the application of such approach, significant tax penalty and default penalty may be avoided. An additional advantage of the self-audit is that in the knowledge of the identified risks, taxpayers can prepare more consciously for a potential NTA audit: it is of crucial importance what information and in which form we hand over to the inspector during the audit.

Furthermore, as a result of a consultation and self-inflected tax audit that takes place prior to a NTA investigation, you can identify unused tax optimization opportunities (e.g. eligibility for tax allowance), which may only be beneficial for the company.

Should you have any questions in connection with the above, our advisors would be pleased to assist you.

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Tax Newsletter 2024/03.

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