An overview by LeitnerLeitner, Taxand Hungary
Hungarian taxpayers subject to the Qualified Domestic Minimum Top-up Tax (QDMTT) must meet new reporting obligations under the global minimum tax (GloBE) rules by the end of December 2024. Companies must declare group membership, provide data on tax calculations, and assign the share of the supplementary tax to domestic group members.
These requirements apply to members of multinational or large domestic groups with consolidated revenues exceeding €750 million in at least two of the last four tax years. Reporting will be required annually going forward, even if the parent company’s country lacks similar rules.
Judit Jancsa-Pék from our Hungarian member firm LeitnerLeitner provides further details of these reporting obligations below.
NEWS: The first global minimum tax notification obligation is finally here
Are you prepared for the 31 December reporting deadline in Hungary under the GloBE rules? Our team in Hungary are here to help; read on to find out more about these reporting requirements and please do not hesitate to contact Judit Jancsa-Pék, partner LeitnerLeitner / Taxand Hungary.
Although the first global minimum tax return is still a long way off for those affected, an important task is here to complete even before the year ends.
Namely, Hungarian taxpayers subject to the QDMTT (Qualified Domestic Minimum Top-up Tax), the local implementation of the global minimum tax, must declare that the group members are subject to the GloBe supplementary tax, they must present the multinational corporate group or large domestic group to which they belong, and they must even provide data on tax calculations. The deadline for this is December 31st before the end of this year respective the 2024 financial and tax year.
Within the Globe reporting obligation, the Hungarian domestic group member or its representative must indicate the data and classification of the group members, as well as the share of the supplementary tax that can be assigned to them, in addition to the structure of the corporate group. The designated representative acts on behalf of all domestic group members.
At the beginning of this year, the domestic legislation regulating the global minimum tax came into force in Hungary, the subjects of which are members of multinational corporate groups or large domestic corporate groups, where the consolidated annual revenue of the ultimate parent company reaches or exceeds EUR 750 million in at least two of the four tax years immediately preceding the tax year, meaning that taxpayers who typically file CbCR must also expect additional burdens arising from the GloBe.
Globe notification/reporting obligations – in addition to the “normal” QDMTT tax return – will later have to be repeated annually. In addition, since it is not certain that a similar reporting obligation also exists in the country of the parent company, as not all countries use this regulation, domestic group members must pay special attention to this in order to avoid later sanctions.
At LeitnerLeitner / Taxand Hungary, a specialized team is at your assistance in full-scope advisory and assistance also regarding the global minimum tax.
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