Finance · Brief

NAV trust-management audits start in mid-November

NAV has announced audits affecting more than a thousand trust arrangements and private foundations. Economic substance and actual operation will be central to the reviews.

NAV will start auditing trust arrangements and private foundations in mid-November, affecting more than a thousand structures according to its 4 November announcement. For Hungarian settlors and trustees, documenting actual operation alongside contractual objectives will matter.

The authority will focus on economic substance and promised practical guidance this week. The announcement describes the start of an audit programme; membership of the affected group does not establish wrongdoing by any particular organisation.

A practical preparation question is whether an individual transaction's history can be traced through original documents. Matching dates, decisions and performance helps distinguish a missing record from a substantive inconsistency. Any later replacement or explanation of a missing document should also retain its actual creation date; a press release does not support retrospective legal conclusions.

The EU list concerning international tax cooperation addresses compliance with a different scope. The MNB market-supervision information portal provides context for checking financial service providers. These issues should be treated separately from the procedure of a domestic tax audit. The next development to watch is NAV's promised guidance with examples, which may clarify the situations the authority emphasises.

Source: the linked NAV announcement.

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Budapest Global Review: NAV trust-management audits start in mid-November. Budapest Global Review, 4 November 2026. https://globalreview.hu/en/cikk/nav-bizalmi-vagyonkezeles-ellenorzes-november-2026

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