Important global minimum tax deadline is approaching in Hungary
As summer comes to an end, we are approaching another tax milestone: 20 November 2025. Hungarian constituent entities (members of multinational groups subject to GloBE rules) should submit their Hungarian Qualified Domestic Minimum Top-up Tax (QDMTT) advance return for the fiscal year ending on 31 December 2024 by this date.
First and foremost, we would like to clarify a common yet risky misconception: electing to apply the transitional CbCR safe harbour does not provide exemption from Hungarian QDMTT advance return submission obligation.
Although the related tax return form is not yet available, the tax authority is expected to publish it within the next one or two weeks: it is advisable to start preparing in time. The affected constituent entities should determine by 20 November whether they are eligible for transitional safe harbour and calculate the amount of their advance tax liability.
Both the review of eligibility for safe harbour and the calculation of the QDMTT advance are complex, time-consuming processes. Considering that the amount of the QDMTT advance should equal the annual QDMTT liability, it is worth gathering the necessary information and beginning the calculations well in advance.
Delays can have serious consequences, as the tax authority may impose a fine of HUF 10 million (approx. EUR 25,500) per constituent entity for failure to submit the return, late submission, or incomplete/incorrect completion. Additionally, late payment of the QDMTT advance will result in interest payment obligations. The respective entity may be exempted from the fine if they acted as expected in the given situation. However, a reference to this exemption requires a detailed examination of the circumstances.
Our expert team is ready to assist you with preparing the QDMTT advance calculation, conducting safe harbour eligibility reviews, and professionally preparing and submitting your tax return. Feel free to contact us and begin timely preparation for this complex tax obligation.
