In our previous blog post we summarized what Hungarian group members need to prepare for in relation to their 2024 global minimum tax (GloBE) obligations. Two important updates have now arrived: the Hungarian Tax Authority (NAV) has published the draft of form 24GLBADO for filing the advance payment of the Qualified Domestic Minimum Top-up Tax (QDMTT), and a bill has been submitted to Parliament under number T/12802 concerning, among other things, reporting and automatic exchange of information related to the GloBE top-up tax. Below we summarize the key points regarding the draft return and the bill.
NAV has not yet released the dedicated form. Based on prior experience with the GLOBE registration form, we expect it to be available exclusively on the ONYA (Online Form-Filling Application) platform. The legislation suggests the return will likely require only the amount of the advance (it is equal to the amount of qualified domestic top-up tax expected to be payable for the tax year), without detailed group information or a full top-up calculation.
Brief recap and key deadlines
Hungarian members of multinational enterprise (MNE) groups must file their first GloBE-based QDMTT advance return and pay the advance to NAV in 2025. This must be completed by the 20th day of the 11th month following the tax year, i.e. by 20 November 2025 for calendar-year taxpayers.
At the domestic group level, the return providing data related to the top-up tax must be submitted to NAV within 15 months from the last day of the tax year (or 18 months for the first tax year in which the GloBE rules apply). For the 2024 calendar year, this means 30 June 2026.
On 14 April 2025, the Council of the European Union adopted the DAC9 directive, which introduces a standardized reporting template and new rules on automatic exchange of information to facilitate GloBE top-up tax reporting and related information exchange between tax authorities. The purpose of the bill is to transpose this directive into Hungarian law.
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General information on the 24GLBADO return
The return may be filed either by the domestic group entity itself or by a designated local entity acting on its behalf. It can be filed in three currencies: in addition to HUF, EUR or USD may be chosen. If HUF is selected, monetary amounts must be reported rounded to the nearest thousand forints. If EUR or USD is selected, amounts must be rounded to the nearest whole number. The general rules of rounding apply.
NAV has set up separate bank account numbers for payment of the GloBE top-up tax by currency:
- HUF: 10032000-01076019-09060018, tax type code: 422
- EUR: 10032000-01076019-09060025, tax type code: 496
- USD: 10032000-01076019-09060032, tax type code: 497
The return will be available via the Online Form-Filling Application (ONYA). The main sections of the return are:
- Identification data,
- Taxpayer details,
- Case handler’s details,
- Characteristics of the return (filing period; type of return: original or correction; filer: domestic group member or designated local entity acting on behalf of all domestic group members),
- Ultimate parent entity (entities) details,
- Aggregated data on QDMTT advance (amount and number of taxpayers),
- Group members’ details, advance payment obligations and declarations.
Where an exemption (e.g., Safe Harbour), an exception (the de minimis rule), or an exclusion applies (first five years of an MNE group’s initial international activity, or first five years of a large domestic group’s liability), the field for the QDMTT advance payable by the group member must show zero, and the code for the applicable relief must be indicated in the declaration field.
If one or more designated group members bear the advance payment obligation, any group member not required to pay must enter zero in its QDMTT advance field and indicate in the declaration the appropriate code stating that another group member bears the payment obligation.
GloBE-related data reporting and automatic exchange of information
It is important to note that the content of bill T/12802, which implements DAC9, may still change during the legislative process. Nevertheless, the main direction is clear: standardized electronic filing and broad automatic information exchange will be introduced for GloBE top-up tax purposes. GloBE data must be filed electronically using the NAV-prescribed form; its detailed data content will be set by ministerial decree, while the bill defines the core data elements.
Under automatic exchange of information, NAV will transmit relevant data from the GloBE top-up tax return to the affected jurisdictions. As a rule, NAV will complete the exchange within 3 months from the filing deadline (or from the actual filing date in case of late filing). As a transitional rule, for the first reportable tax year (i.e., tax years beginning after 31 December 2023), NAV will transmit the data within 6 months to the relevant jurisdictions. Furthermore, NAV will first perform such data exchange after 1 December 2026.
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The structure of the GloBE top-up tax data reporting will be as follows:
- Information on the Multinational Enterprise Group
- Identification of the reporting group member
- General information on the MNE Group
- The MNE Group and the tax year covered by the report
- General accounting information on the MNE Group
- Organizational structure
- Ultimate parent entity
- Group entities other than the UPE and members of joint venture groups
- Changes in the corporate structure during the tax year covered by the report
- High-level summary of the information
- Jurisdiction-specific exemptions and exclusions
- Jurisdiction characteristics
- Elections applicable for the jurisdiction (reduction of the top-up tax to 0%)
- Jurisdictional exemption election
- Election of the de minimis exclusion (exception from the top-up tax)
- MNE Group in the initial phase of its international activity (if relevant)
- Calculations
- Jurisdiction characteristics
- Effective tax rate (ETR) calculation
- Effective tax rate
- Jurisdiction-level calculations relating to deferred tax accounting
- Elections applied for the jurisdiction (if any)
- Entity-level calculations
- Top-up tax calculation
- Top-up tax
- Calculation of the substance-based income exclusion (where applicable)
- Top-up tax surplus
- Qualified Domestic Minimum Top-up Tax (QDMTT)
- Allocation and attribution of the top-up tax (if relevant)
- Application of the Income Inclusion Rule (IIR) for the jurisdiction
- Total top-up tax under the Undertaxed Payments Rule (UTPR) for the jurisdiction
- Attribution of the top-up tax under the UTPR
Why involve an expert?
As a general rule, every subject to GloBE taxpayer must file the 24GLBADO return by 20 November 2025, regardless of whether an exemption is claimed or no actual top-up tax liability arises. Failure to file, late filing, or incorrect filing may result in a default penalty of up to HUF 10 million (unless the taxpayer can demonstrate that it acted as could reasonably be expected under the circumstances). It is therefore advisable to devote particular attention - and do so in due time - to exemption assessments, the ETR calculation, and the QDMTT computation. The GloBE framework diverges significantly from familiar Hungarian corporate tax practices, and even minor oversights can create serious risks, so seeking expert support for the advance return filing is recommended.
This blog post was written byJózsef Vizer, Lead Tax Advisor at ICT Business Advisory Zrt.
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Legal statement
This article is for informational purposes only and does not constitute tax advice. Before making any specific decisions, please seek personalized advice from our experts.
