By 2026, the legal and technical framework for the global minimum tax appears to be taking shape. The detailed rules in Hungary are provided by two decrees of the Hungarian Ministry for National Economy (NGM). Decree 46/2025 (XII. 23.) NGM defines the specific data structure and tables of the GIR, ensuring EU compatibility, while Decree 38/2025 (XII. 19.) NGM directly incorporates the most important exemption rules into Hungarian law. These include the transitional CbCR Safe Harbour until 2026, the simplification for smaller/insignificant group members, and the UTPR exemption until the end of 2026 for parent companies with high tax rates. Together, these steps indicate that the global minimum tax system is becoming more functional and more manageable from an administrative perspective.
DAC9: Simplified administration
Furthermore, thanks to the DAC9 Directive, which provides for unified European implementation, the administrative burden is significantly reduced: corporate groups only need to submit the GloBE Information Return (GIR) data report in a single member state, and the data is automatically shared with the tax authorities of the relevant countries. The Hungarian legal system has implemented this through the amendment of Act XXXVII of 2013 and Act XC of 2025, the latter of which also promulgated the multilateral agreement ensuring automatic data exchange with non-EU countries (such as the United Kingdom or Canada).
Two new Safe Harbours
In addition, the “Side-by-Side” package published by the OECD on January 5, 2026, brought a breakthrough in the transatlantic debate, officially recognizing the US tax system as equivalent with the global minimum tax rules. As a result, from January 1, 2026, two new Safe Harbours have entered into force. The SbS Safe Harbour exempts those corporate groups from top-up taxes (IIR, UTPR) whose parent company operates in a recognized – for example, American – jurisdiction, while the UPE Safe Harbour provides protection for parent companies with high tax rates against paying the UTPR. It is important to note, however, that these exemptions are not retroactive, which means they do not affect the Hungarian domestic top-up tax (QDMTT). A significant change is that, under the new rules, the eligibility period for the transitional CbCR Safe Harbour exemption is extended by one year, meaning it will also apply to financial years beginning up to December 31, 2027 – and ending by June 30, 2029 at the latest – with a minimum tax rate of 17% for the simplified effective tax rate test.
At WTS Klient Hungary, our tax advisors are happy to assist you with all 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.
