The global minimum tax framework enters a new phase in 2026: for the affected corporate groups, the closing of the 2024 tax year and the preparation tasks for 2025 become relevant simultaneously. In the coming months, the parallel handling of reporting, data reporting and accounting obligations will therefore come into focus, while uncertainty remains in several practical areas.

The practical application of the global minimum tax (Pillar 2) rules enters a new, substantive compliance phase in 2026, making the closing of 2024 and the year-end tasks for 2025 simultaneously relevant for several corporate groups, thus requiring the parallel management of reporting and tax planning processes.

The 2024 tax year cannot yet be considered closed from the perspective of the Qualified Domestic Minimum Top-up Tax (QDMTT), as the final settlement return has not yet been submitted, while calculation/accounting tasks already arise in relation to the 2025 tax year, considering that these items must also be presented in the annual financial statements as accrued expenses and deferred charges.

The final QDMTT filing deadline expires on 30 June

An important amendment is that although many taxpayers regard the QDMTT as an advance payment and therefore already consider it closed, a final QDMTT return and an Income Inclusion Rule (IIR) return relating to the additional tax under the income inclusion rule must still be submitted for the 2024 tax year in addition to the advance tax return. The legislator has expanded the function of the previous advance return, therefore this form will also serve for the submission of the full settlement return.

The filing deadline for the first QDMTT return relating to calendar-year groups for 2024 expires on 30 June 2026, as the extended 18-month deadline expires on that date. This applies to all affected taxpayers, regardless of whether an actual tax payment obligation arises.

According to the latest information, the tax authority is already working on the final filing structure:

• the draft version of form 24GLBADO, expanded with final settlement return sections, has already been prepared and is available on the tax authority’s website,
• the completion guide has been published,
• and documentation supporting the preparation of the XML file has also been released.

During the development process, the content of the global minimum tax reporting obligation under DAC9 is also being taken into account, considering that the introduction of this obligation is closely linked to the already known global minimum tax rules and their international harmonisation. The return will continue to be submitted through the Online Form Filling Application (ONYA) web platform.

The safe harbour election cannot be made retrospectively

It is particularly important that the application of the so-called safe harbour exemptions must be expressly indicated in the tax return, and failure to do so cannot subsequently be remedied. This may have long-term consequences for the determination of the tax liability, considering that in the absence of the initial election, the affected taxpayers may not apply the exemption in subsequent tax years either.

In addition to the QDMTT, the submission of the GloBe Information Return (GIR) may also be required. If the company itself does not submit the GIR, the Hungarian tax authority must also be informed which related party entity fulfils the GIR obligation. A further 6-month deadline applies to this notification obligation.

Data collection and reconciliations may be time-consuming

Due to the current uncertainties, corporate groups should begin preparations already now, as compliance represents not only a tax challenge, but also a data and process-related challenge.

Based on our experience, the collection and reconciliation of the required data and the assessment of safe harbour eligibility may take several weeks, therefore preparations should not be postponed.

Non-compliance may involve significant financial risks

The Hungarian tax authority treats compliance with the global minimum tax rules as a priority area, therefore failure to meet deadlines or incomplete reporting may result in actual financial risks.

Failure to comply with filing and reporting obligations may result in a default penalty of up to HUF 10 million if the return relating to the fulfilment of the obligations is submitted incompletely or late.

How can Grant Thornton help?

Should you have any questions regarding the application of the global minimum tax rules, the assessment of safe harbour eligibility or the fulfilment of filing obligations, Grant Thornton’s experts are ready to support you and your company.

***

This newsletter has been prepared exclusively for general information purposes, based on the information available on the date of publication, and therefore does not qualify as personalised tax advice in any respect and does not replace such advice.