UPDATE! The draft QDMTT advance tax return has been published on 15 October 2025.
The global minimum tax (Pillar 2) has been one of the most pressing topics for tax and financial professionals, as well as executives of multinational corporations, across the European Union for several years now. This is largely due to the ongoing evolution of regulations related to this tax regime. As a result of changes in EU legislation, several amendments and clarifications have recently been proposed in Hungary as well. The latest developments concern global data exchange and the application of transitional CbCR safe harbour rules under the Pillar 2 framework.
The next step in centralised data reporting: global data exchange
One of the key elements of the latest Hungarian legislative proposal related to Pillar 2 is the introduction of centralised data reporting for Hungarian constituent entities, significantly reducing their administrative burden. The first step in centralised data reporting was the DAC9 Directive, adopted by the European Union in spring. Hungary is in the process of implementing this directive, likely as part of the upcoming autumn tax package.
The new proposal of the Hungarian government prepares the groundwork for data exchange with non-EU jurisdictions. In practice, this means that if a GloBE Information Return (GIR) is filed in a country that has signed a GIR MCAA (Multilateral Competent Authority Agreement) with Hungary, then there will be no need to file the same return again in Hungary. Annex 1 of the draft legislation lists the relevant jurisdictions, including Canada, Japan, the United Kingdom, and Australia, with which Hungary plans to establish such data exchange agreements.
Technical clarifications in the 2025 autumn tax package
In addition to the anticipated implementation of the DAC9 Directive, the 2025 autumn tax package in Hungary will also include several technical and interpretative clarifications concerning the transitional CbCR safe harbour rules set out in the Hungarian 2023 Act LXXXIV on the Global Minimum Tax (Act on GMT).
The two most significant technical clarifications under the Pillar 2 legislation are as follows:
- Refinement of the definition of simplified covered taxes: Taxes that are not reported as income taxes in financial statements will not be eligible as simplified covered taxes. In the Hungarian context, this may affect the local business tax, which – depending on the accounting standards applied – is not classified as an income tax (e.g., under Hungarian accounting rules). While this clarification could already be inferred from the OECD’s background materials, it will now be explicitly incorporated into Hungarian legislation.
- Establishing fixed percentages for substance-based income exclusion: These percentages will support uniform legal interpretation among Hungarian taxpayers and reduce uncertainty in the application of the Pillar 2 rules.
Filing the Qualified Domestic Minimum Top-up Tax (QDMTT) advance return
Hungarian constituent entities subject to the global minimum tax must submit their QDMTT advance return for the 2024 tax year by 20 November 2025. If an advance payment obligation arises, the tax liability must also be paid at the time of filing. It is essential to keep this deadline in mind, as failure to submit the return may result in a penalty of up to HUF 10 million.
UPDATE! Draft QDMTT advance tax return released
To support taxpayers’ preparation, the Hungarian tax authority has published the draft version of the advance tax return for the Qualified Domestic Minimum Top-up Tax (QDMTT), the 24GLBADO form. Apart from the draft tax return form, the filling instruction and a supporting document in XML format to assist in electronic submission have also been released. The return will be filed through the ONYA online platform (Hungarian online document management webpage), and – as expected – must be submitted even if the taxpayer has no advance payment obligation.
Taxpayers will have limited time to interpret and complete the QDMTT advance return. At WTS Klient Hungary, our tax advisors are happy to assist you with this return or any other questions related to Pillar 2 compliance. As part of our comprehensive tax planning and advisory services, we not only explain the relevant rules in detail but also develop tailor-made, optimal solutions for your business. Feel free to contact us!
This article provides general information and does not constitute advice.
