Filing of the 2024 top-up tax return
The QDMTT and IIR tax for 2024 must be reported using the extended form 24GLOBADO.
For taxpayers whose financial year corresponds to the 2024 calendar year, the return must be filed by 30 June 2026. Any top-up tax due in excess of the QDMTT advance payments already made must also be paid by that date. At the time of writing, no extension of the tax return filing and payment deadline has been announced.
The filing obligation applies to all Hungarian constituent entities that fell within the scope of the global minimum tax in the 2024 financial year. This obligation applies irrespective of whether the constituent entity actually has a QDMTT or IIR top-up tax liability in Hungary for 2024. Accordingly, the QDMTT return should be submitted even if temporary safe harbor applies in respect of Hungary for 2024.
Constituent entities may file the return individually, or a designated entity may fulfill the filing obligation on behalf of all Hungarian constituent entities.
Content of the return
Based on the form, the following information must be included in the return:
- The identification details of the UPE and the Hungarian constituent entities
- The amount of QDMTT and IIR tax payable (in total for Hungary and broken down by constituent entity)
- The ETR for Hungary and, where applicable, for any Hungarian subgroups
- The amount of QDMTT advances already declared and paid, broken down by constituent entity
- The accounting standard and currency used to determine the QDMTT liability, the currency of the consolidated financial statements, details of any excluded entities, and certain GloBE elections applied, etc
- The identification of any subgroups within the MNE group, if applicable
- The status of the parent entity where the Hungarian constituent entity qualifies as a parent entity
Review of calculations
Although the form does not require detailed calculations to be included, the accurate determination of any top-up tax liability may require a review and, where necessary, an update of the preliminary calculations previously prepared for the 2024 year-end closing and the QDMTT advance tax return. This is particularly relevant where those calculations were prepared solely on the basis of the UPE’s accounting standard. We are available to assist you in this process, including the review and fine-tuning of the calculations.
Potential penalties
Please note that incorrect filing, late submission of the tax return, or failure to file at all may result in a default penalty of up to HUF 10,000,000 (approx. EUR 27,800).
Should you require any assistance with the preparation or submission of the return, our advisors remain at your disposal.
