Upcoming obligations related to the global minimum tax (GloBE)

Advanced payment and filing by 20 November 2025

• Hungarian located Constituent Entities operating on a calendar year basis are required to file an advance tax return and pay any potential advance for QDMTT by 20 November 2025.

• Although the form for the advance tax return is not yet available and several important details regarding the global minimum tax are still unknown, it is time to review the calculations already prepared, even if those do not yet cover all detailed questions. Where necessary, these should be revised and finalized, and we are happy to assist you in this process.

Review of calculations

• In our experience, the preparation of calculations related to the global minimum tax often raises numerous interpretational questions that may lead to potential risks, due to the complex and extensive legal background (or, in some cases, the lack of regulation). Such issues include, for example, the correct selection of the applicable accounting standard, the treatment of financial years differing from that of the ultimate parent or other Constituent Entities, the applicability of transitional safe harbours, the calculation of Substance Based Carve Out, and the utilization of historical carry-forward losses and tax credits, etc. As these issues can significantly affect the amount of top-up tax actually payable, particular care must be taken when preparing the calculations.

• Certain elections must be made already in the first year, which may affect not only the current year but also the tax obligations of subsequent years. An inaccurate election may result in unnecessary tax burdens in later years, without the possibility of subsequent correction. Our advisors are already available to help you avoid such situations.

Potential sanctions

• Failure to file or pay the QDMTT advance, or submitting the return late or incorrectly, may result in significant penalties; the default penalty alone can be as much as HUF 10 million. Please note that the possibility of temporary relief from adverse tax consequences is far from automatic, so when fulfilling your tax obligations – especially since the relevant Hungarian financial statements are already available – we recommend exercising the utmost care.

As soon as further information becomes available regarding the form and the detailed regulations, we will contact you.