Global Minimum Tax in the Context of Year-End Closing and Financial Statement Preparation
From the perspective of the global minimum tax (GloBE), 2026 can no longer be regarded merely as a preparatory period, but rather as a period of full compliance, during which corporate groups must simultaneously address their notification, tax return filing, data reporting and accounting obligations, as well as newly introduced professional interpretations, all of this — in light of the extended deadlines — in respect of multiple tax years.
GloBE notification
With respect to the 2025 financial year, the first step is to confirm whether the corporate group falls within the scope of the rules, with particular regard to meeting the EUR 750 million consolidated revenue threshold, having a presence in multiple jurisdictions, and the involvement of the Hungarian group member. Thereafter, fulfilling the GloBE notification obligation is of key importance, the deadline for which was changed in 2025: instead of the previous year-end deadline, the notification must now be submitted by the last day of the second month following the financial year. Accordingly, for taxpayers whose tax year coincides with the calendar year, the notification for 2025 had to be submitted by 2 March 2026 on the form titled “GLOBE”. The scope of data to be reported in the notification has also been expanded to include, among other things, information relating to data reporting under the GIR/DAC9 rules, the status of the designated local entity, and information on whether the taxpayer qualifies as a joint venture or as part of a group of enterprises.
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Exemption or top-up tax?
Following the identification of the tax obligation, the next step is to assess whether the Hungarian group members may be eligible to apply any exemption rule (i.e. a Safe Harbour based on CbCR, meaning country-by-country reporting data), thereby avoiding the often highly complex calculation of the qualified domestic minimum top-up tax (QDMTT). Although there is no explicit statutory deadline for carrying out the Safe Harbour assessment, it is advisable to complete it no later than the finalisation of the 2025 financial statements.The application of exemption rules may significantly reduce the administrative burden associated with GloBE; however, taxpayers are required to properly substantiate the fulfilment of the exemption conditions, and therefore an insufficiently thorough assessment and documentation may give rise to significant tax risk during a tax audit.
When fulfilling accounting obligations, the annual financial statements prepared for the 2025 financial year — which, in the case of a financial year identical to the calendar year, must be approved by 31 May 2026— must already reflect the impact of the global minimum tax. In line with the general principles of accounting, the top-up tax must be recognised as a tax charge relating to the current year, regardless of the fact that the filing and financial settlement of such tax will only become due in subsequent financial years. If the exact amount is not yet available, the use of estimates may be justified, supported by appropriate substantiation and detailed disclosure in the notes to the financial statements.
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Filing of the top-up tax return
Thereafter, the detailed data reporting obligation related to the global minimum tax, namely the GloBE Information Return (GIR),becomes due. The rules applicable to the GIR are set out in Decree No. 46/2025 (NGM), which also establishes the framework for international exchange of information. As a general rule, the GIR must be submitted within 15 months following the tax year (with an extended deadline of 18 months in the first year of application), which, for the 2024 tax year in the case of calendar-year taxpayers, falls due on 30 June 2026.The GIR contains substantially more detailed information than the annual tax return: on a jurisdiction-by-jurisdiction basis, it includes, among other things, financial and tax data, the calculation of the effective tax rate (ETR), and the information necessary for determining the top-up tax.
The GIR does not necessarily have to be submitted in Hungary, as the Hungarian rules also recognise data reporting completed in another jurisdiction. The condition for this is that the relevant jurisdiction must be a party to the multilateral agreement that provides for the automatic exchange of the information reported in the GIR among the affected tax authorities. In such cases, the information included in the GIR submitted in the other state is also transmitted to Hungary by the competent tax authority, allowing the Hungarian group members to be exempted from the obligation of duplicate data reporting.
In parallel with the GIR, the filing of the qualified domestic minimum top-up tax return is also due; however, unlike in the case of the GIR, no exemption is available from this obligation. Domestic group members are required to submit their top-up tax returns for the 2024 tax year — where the tax year coincides with the calendar year — by 30 June 2026and by the same date they must also settle the portion of their top-up tax liability that has not yet been paid as an advance.
Top-up tax advance return
As discussed in detail in our previous blog post, the Hungarian members of multinational enterprise groups are required to file a qualified domestic minimum top-up tax advance returnand pay the corresponding tax advance to the Hungarian tax authority (NAV). This is due on the 20th day of the eleventh month following the tax year, which, for calendar-year taxpayers in respect of the 2025 tax year, is 20 November 2026..
Key considerations in relation to the annual financial statements
When preparing the annual financial statements, one of the first points to assess in relation to the global minimum tax is whether the Hungarian group members may apply any Safe Harbour exemption rule, as this may significantly simplify the related calculations and administrative obligations. In addition, it is advisable to review the balances of deferred tax assets and deferred tax liabilities,with particular attention to the impact these may have on calculations relevant for global minimum tax purposes. If the exemption rules cannot be applied, the detailed determination of the qualified domestic minimum top-up tax liability also becomes necessary, requiring a coordinated analysis of accounting and tax data. At the same time, the top-up tax liability must be appropriately presented in the financial statements, where necessary relying on estimates and on information detailed in the notes to the financial statements. It is therefore clear that, in the course of the year-end closing process, the global minimum tax represents not merely another tax issue, but a separate and complex area of analysis in its own right. In view of the complexity of the rules, as well as the broad range of applicable domestic and international provisions, the involvement of an expert may be particularly justified in order to ensure compliance and the proper management of risks. be kell mutatni a kiegészítőadó kötelezettséget, szükség esetén becslésekre és kiegészítő mellékletben részletezett információkra támaszkodva. Jól látható tehát, hogy a globális minimumadó az éves zárás során nem pusztán egy újabb adózási kérdés, hanem önálló és összetett elemzési terület. A szabályozás bonyolultsága, valamint a kapcsolódó hazai és nemzetközi előírások sokrétűsége miatt a megfelelés biztosítása és a kockázatok megfelelő kezelése érdekében kifejezetten indokolt lehet szakértő bevonása.
Author: Beáta Guti, Tax Consultant and
József Vizer, Partner and Lead Consultant, Advisory
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