An important deadline is approaching for corporate groups falling within the scope of the global minimum tax in Hungary. For taxpayers with a calendar tax year, the qualified domestic minimum top-up tax (QDMTT) advance tax return for the 2025 tax year must be submitted by 20 November 2026. If a tax payment obligation arises, the advance tax must also be paid by this date. Following the introduction of the global minimum tax in Hungary, affected corporate groups were required to fulfil this obligation for the first time last autumn.
The obligation to file a global minimum tax advance return is prescribed by Act LXXXIV of 2023 implementing the global minimum tax rules, as well as by the detailed implementing rules, and may affect the Hungarian group members of multinational and large-scale domestic corporate groups falling within its scope.
It is important to emphasise that the application of a transitional safe harbour does not in itself exempt taxpayers from the filing obligation. Eligibility for the exemption must be indicated in the return, and the assessment and detailed documentation of such eligibility is a key task for companies.
What data must be reviewed for the global minimum tax advance return?
Calculations related to the global minimum tax differ significantly from traditional corporate income tax calculations. Among other things, taxpayers must review:
- the effective tax rate (ETR),
- the covered taxes,
- any applicable exemptions and reliefs,
- as well as group-level data.
The task is particularly complex for corporate groups operating in multiple jurisdictions, where the necessary information may originate from different systems or group-level reports. For this reason, the required calculations and reconciliations may require lengthy preparation, making it advisable to start well in advance.
What are the consequences of non-compliance?
If the deadline is missed or the return is submitted inaccurately, the Hungarian tax authority may impose a default penalty. In addition, late payment interest may be charged on any advance tax paid after the deadline. Although the legislation provides an opportunity to demonstrate that the taxpayer acted in good faith, the burden of proof rests with the taxpayer.
What should companies do as the deadline approaches?
The 20 November deadline for the global minimum tax advance return represents an important milestone for affected corporate groups in Hungary. To ensure that obligations can be fulfilled properly and on time, it is advisable to:
- review the group’s global minimum tax position,
- complete the necessary calculations,
- and ensure the availability of the data and supporting documentation required for the return.
Advance tax calculations and filing obligations related to the global minimum tax can raise numerous technical and practical questions, particularly for international corporate groups. Our experts provide support in assessing global minimum tax obligations, reviewing exemption conditions, calculating the QDMTT advance tax, fulfilling filing obligations, and preparing and reviewing supporting documentation.
This article is for general information purposes only and should not be considered as advice.
