QDMTT advance return draft published by the Hungarian Tax Authority

Please be informed that the Hungarian Tax Authority has published its first draft with respect to the long-awaited QDMTT advance return due for filing by 20 November 2025 (for FY24 for calendar-year groups). It is important to note that the published form is still a draft, further modifications to the final version of the QDMTT advance return form are possible. As expected, there will be a possibility to appoint one designated local entity who will declare the QDMTT payable (or exemption) on behalf of all local constituent entities.

According to the draft tax return form, the reportable data points will include:

• identification details of the Hungarian constituent entities and the UPEs,
• amount of QDMTT advance payable per constituent entity (determined either in HUF, EUR, or USD per the applicable QDMTT rules), and
• further declarations if any of the Hungarian constituent entities does not have any QDMTT payable (e.g., indicating the relevant Transitional CbCR Safe Harbour test which is passed).

It follows from the above that the Hungarian constituent entities should also elect one of the four methods provided by the Hungarian QDMTT legislation to allocate the QDMTT liability among themselves:

a) allocating the tax liability in proportion to their GloBE Income,

b) allocating the tax liability in proportion to their Excess Profit,

c) allocating the tax liability either according to point a) or b) but only among those constituent entities that are fully owned by the Parent Entity, or

d) designating one local entity who is liable for the whole amount of the jurisdictional top-up tax.

Please also note that the ministerial decree that is expected to provide the detailed rule of the Transitional CbCR Safe Harbour has not been released yet. Therefore, we suggest reviewing any assessments made with respect to the Transitional CbCR Safe Harbour position for Hungarian QDMTT purposes when the related rules are issued. Also, there may be special cases that cannot be properly administered by the released draft return. Therefore, further discussion on a case-by-case basis is recommended where the proper declarations cannot be made in the form.