From next year, it will be easier for multinational groups (MNEs) to comply with the administrative obligations related to the global minimum tax (GloBE), including by allowing them to submit the global minimum tax return centrally. The simplification follows the adoption on 14 April 2025 by the Council of the European Union of the proposal published by the European Commission in October for a Directive on Administrative Cooperation (DAC9), which will require closer cooperation and a smoother exchange of information between EU tax administrations.
What is the simplification about?
One important innovation of DAC9 is that it allows for the centralised filing of a global minimum tax return. This means that the parent company or a designated group member can submit the new return, updated in January, on behalf of the group for all members of the group, instead of each of them having to do it separately in their own country. A standardised Top-up Tax Information Return (TTIR) will be introduced within the EU and Member States will automatically share data relating to the global minimum tax.
A possible consequence of the change is that group members will be less involved in the return process at national level, but intra-group data reporting should still be encouraged.
What are the key deadlines?
The Directive provisions adopted at EU level must be transposed into national law by Member States by 31 December 2025. The change will also affect the financial year 2024, for which the reporting obligation will have to be fulfilled by 30 June 2026 at the latest. The deadline for transmitting the data to the relevant tax authorities is 31 December 2026, but for subsequent years the deadline will be three months from the date of receipt of the return.
Which group member should submit the global minimum tax return?
Consideration should be given as to which group member jurisdiction is the most appropriate to submit the global minimum tax return, i.e. which group member should be designated for this task. A possible consideration in this decision is whether a particular group member is covered by a temporary exemption (e.g. CbCR exemption, etc.) or, in the absence of such an exemption, whether the data required for GloBE compliance is already being collected.
Since the exchange of data will only be automatic within the European Union, if the group has a non-EU (third country) group member, it is also necessary to check whether the country concerned has acceded to the OECD (Organisation for Economic Co-operation and Development) Multilateral Competent Authority Agreement on the Exchange of GloBEInformation (GIR MCAA). If it has not acceded, it may still be obliged to submit a local global minimum tax return.
A transitional simplified jurisdictional reporting framework (Simplified Framework) will also be available as a transitional option, which could reduce the administrative burden for businesses.
What else should businesses look out for?
It is recommended to review reporting requirements in a timely manner to ensure that the systems used by the company are able to accurately capture and report the required information to ensure that the return obligation is properly fulfilled.
It is important to keep abreast of any changes in the regulatory background to the OECD’s Global Minimum Tax Information Return (GIR) and the EU’s Form TTIR.
It is also important to be aware of and comply with the rules because the 2025 tax inspection plan of the Hungarian tax authority concerning GloBE includes a priority review of the so-called covered taxes (corporate tax, innovation contribution, etc.).
Given that the top-up tax liability is already required to be included in the 2024 financial statement, the Hungarian companies concerned will have to perform the global minimum tax calculation shortly. The tax advisors at WTS Klient Hungary will be happy to assist you with the calculation and any other questions related to the global minimum tax return. As part of our tax planning and consulting services, we not only explain the details of the rules, but also develop the most optimal solutions tailored to your company. Contact us with confidence!
This article provides general information and does not constitute advice.
