2025-18-10
On 15 October 2025, the Hungarian Tax Authority issued the draft Advance Qualifying Domestic Minimum Top-Up Tax Declaration Form 24GLBADO. It is possible that further amendments will be made to the draft (particularly since the underlying decree has not yet been published). Nevertheless, the main directions are already taking shape, and we provide a brief summary of them below.
Scope of Entities Required to File the Return
The obligation to file the advance return applies to all Hungarian-based Constituent Entities, regardless of whether they have an actual QDMTT payment liability for 2024. Accordingly, the completed form must also be submitted—under penalty for late filing—by those Constituent Entities that benefit from any exemption (such as the CbC Safe Harbour) as well as those who, based on their detailed calculations, have determined that they are not subject to QDMTT.
Minimum Data Content
According to the draft form, in addition to the identification data of the Constituent Entity and the Ultimate Parent Entity, only the amount of the top-up tax advance needs to be included in the return, both in aggregate and broken down by Constituent Entity.
However, in the case of indicating a nil advance, a declaration must be made for the relevant Constituent Entity stating the reason for the absence of the advance payment — whether it is due to one of the seven exemption reasons listed, or because the payment obligation is borne by another Constituent Entity.
Submission Options Similar to Registration
The return can only be submitted via the ONYA platform and only by the taxpayer and their authorized representative, provided that the representative’s authorization has been registered in advance with the tax authority (NAV).
It is also possible to designate a Hungarian Constituent Entity to act on behalf of all Hungarian Constituent Entities for the purposes of submitting the return and paying the tax.
Potential Sanctions
Failure to file or pay the QDMTT advance, or to submit the return on accurately and on time, may result in substantial penalties. The default penalty alone can reach up to HUF 10 million.
Please note that temporary relief from adverse tax consequences is by no means automatic. As the relevant Hungarian financial statements are already available, we strongly recommend exercising the utmost care when fulfilling your tax obligations.
Our colleagues are available to help you should you require any assistance with the completion and submission of the advance return.
