The deadline for global minimum tax registration is approaching

We would like to bring some important updates to your attention regarding the Hungarian Pillar Two compliance obligations. Since 2024, Hungarian Constituent Entities are generally obliged to notify the Hungarian Tax Authority (HTA) annually on a specific form about their taxpayer status for Hungarian GloBE purposes. Starting from the summer of 2025, this notification should be submitted to the HTA by the end of the second month following the given tax year (for calendar-year groups, the FY25 submission deadline is 2 March 2026, considering that 28 February falls on a weekend).

The Ministry for National Economy published a decree on the detailed rules of the completion of GloBE related reporting, tax return preparation and payment obligations. Based on it, entities are required to provide significantly increased amount of data on the FY25 notification form compared to the previous version of the form.

Based on the decree, the following data is required in the notification form for 2025:

• The name, Hungarian tax ID, EU tax ID (if applicable), and country of residence of the ultimate parent entity of the group.
• The name, Hungarian tax ID and EU tax ID (if applicable) of the Hungarian Constituent Entities.
• The name and identification details of the Hungarian Constituent Entities designated for the payment of the applicable top-up tax (QDMTT, QDMTT advance, IIR, UTPR), as well as for the submission of the related tax (advance) returns for the relevant tax year.
• The name and identification details of the constituent entity submitting the GloBE Information Return (GIR) for the relevant tax year.
• The identification details of taxpayers qualifying as Hungarian joint ventures and joint venture groups.

Considering the above, it may also be necessary to accelerate certain decision-making processes about the GloBE obligations of the Constituent Entities (for example, appointing the Hungarian Constituent Entity designated for the payment of the Hungarian QDMTT advance liability). To ease the associated time pressure, the draft decree provides the opportunity to correct the form after the submission in case of changes in the relevant data.

In case of late submission of the notification, the HTA may impose a penalty of five million HUF (approx. 13,000 EUR) per Hungarian Constituent Entity. Considering the expected changes to the notification form and the potential fines, it is crucial to start preparing for the submission of the notification form.

Our experts are happy to assist in the preparation and submission of the notification, as well as answering any questions that may arise during the process. If you find our support helpful, you can reach out to us at the following contact details.