The autumn tax package proposal submitted on 29 October 2024 does not contain any changes compared to the version published for public consultation regarding the reporting obligation of taxpayers subject to the Act on Top-Up Taxes Ensuring a Global Minimum Level of Taxation (‘Global Minimum Tax Act’). As a result, the domestic constituent entity or the designated domestic entity acting on its behalf whose fiscal year ends on 31 December or was terminated during the year of 2024 shall fulfill its reporting obligation until 31 December 2024.
The declaration form has not yet been made available on the National Tax and Customs Administration of Hungary’s website. However, the proposal lists the following data, which must be reported:
- the identification data of constituent entities of multinational enterprise groups or large-scale domestic groups, including their VAT number, intra-community VAT number, residency as well as their qualification as per the Global Minimum Tax Act;
- information regarding the group’s general company structure, including information pertaining to the controlling shares held by constituent entities in other constituent entities.
This means that the proposal requires a significant amount of information to be provided not only in connection with the domestic constituent entities, but also the whole enterprise group, thereby imposing a significant burden on those who are constituent entities of a multinational enterprise group with a complex structure and a large number of constituent entities.
In order to meet the prescribed deadline, we recommend that companies begin the collection of the aforementioned data as early as possible.
As soon as the declaration form is made available - or as new information is released - we will send out an updated newsletter.
We are, naturally, at your disposal should you need assistance in fulfilling your reporting obligation.
