In 2025, Hungarian members of multinational groups must, for the first time, file a qualified domestic minimum top-up tax advance return based on the GloBE rules and pay the advance to the Hungarian Tax Authority (NAV). Under the Hungarian rules, the return must be filed and the advance paid by the 20th day of the 11th month following the tax year. For calendar-year taxpayers, this is 20 November 2025.
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.
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.
Failure to file can trigger a late-filing penalty of up to HUF 10 million. Importantly, every GloBE taxpayer must file, even if a safe harbour or exemption applies or no top-up tax is actually due.
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Who falls within scope? (personal and material scope)
In-scope groups: Multinational or large domestic groups with consolidated revenue reached or exceeded EUR 750 million in two of the preceding four financial years.
Minimum tax rate: GloBE focuses on the jurisdiction-level Effective Tax Rate (ETR). If the ETR in a country falls below 15%, a top-up tax may arise.
Hungarian mechanism:
- Qualified Domestic Minimum Top-Up Tax (QDMTT) — Hungary’s prime top-up tax collected locally.
- Top-up at higher levels — generally via IIR (Income Inclusion Rule) at the parent, and residual UTPR (Undertaxed Profits Rule) allocation if needed.
- The GloBE mechanism aims to ensure the 15% minimum ETR — first through QDMTT, then via IIR/UTPR as applicable.
How are ETR and the top-up tax computed?
High-level workflow:
- Determine Net Qualifying Income for Hungary: accounting profit after tax adjusted by GloBE rules.
- Determine Covered Taxes and Adjusted Covered Taxes: Corporate Income Tax, Local Business Tax, Income Tax of Energy Suppliers, Innovation Contribution, and other adjustments described by GloBE (e.g. deferred taxes).
- Compute ETR: Adjusted Covered Taxes divided by the Net Qualifying Income.
- Compute Top-up tax where ETR is less than 15%, considering substance-based income exclusion and other reductions.
- Allocation order: QDMTT first, then IIR, and finally UTPR (only from 2025).
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Safe harbours and reliefs
- Transitional CbCR Safe Harbour: The group members of a country may be relieved from detailed GloBE calculations where the de minimis, routine profits, or simplified ETR tests are satisfied. This is time-limited and phases out.
- Permanent De Minimis Exclusion: Where revenue and income are below the threshold in a country, no top-up tax arises.
- Substance-based income exclusion: An annually varying percentage of the eligible payroll cost of eligible employees and the book value of the eligible tangible assets is carved out from the Net Qualifying Income, thereby lowering or even eliminating the top-up tax.
Compliance and deadlines — spotlight on the advance
- Registration: as a subject to GloBE, the taxpayer must register with NAV annually using the GLOBE form that can be completed via ONYA. Before June 20 2025, the notification had to be made within 12 months of the start date of the tax year, and from then on until the last day of the second month following the tax year.
- Advance return & payment: the QDMTT advance must be determined, declared, and paid by the 20th day of the eleventh month after the tax year (20 November 2025 for calendar-year taxpayers).
- What to submit? The form of the advance tax return is not published yet. Expected to be only the advance amount should be declared.
- Penalty exposure: Failure to file, delay in filing, or incorrect filing may lead to a fine of up to HUF 10 million.
- GloBE Invormation Return (GIR): At the domestic group level, it must be submitted to NAV within 15 months from the last day of the tax year (18 months in the case of the first tax year in which they fall under the scope of GloBE) - by 30 June 2026 for the 2024 calendar year. The tax return obligation also exists if the Safe Harbour or other exemption conditions are met.
Common pitfalls to avoid
- When determining the thresholds, the data of the group or members are not converted into Euro using the correct exchange rate. This can easily lead to incorrect conclusions regarding the GloBE subjectivity of the group or the exemption of domestic members.
- Errors in identifying group members, and thus some companies are considered members of more than one group, or vice versa. Such errors can both lead to incorrect conclusions regarding GloBE subjectivity and may result in the failure or unjustified payment of top-up tax.
- When group members keep their books according to several different accounting standards, the group must choose which accounting standard accepted by GloBE to adjust the figures of the different group members. It is a risk if the necessary adjustments are missed.
- Accounting data is incorrectly calculated or adjustments are not made or are made in an inadequate amount when calculating net qualifying income or loss, qualifying revenue, covered taxes and many other relevant values.
- The CbCR data-based Safe Harbour is available for the first 3 years of tax liability if group members chose it in the first year. If the group members fail to choose it in the first year, domestic members will no longer be eligible for the exemption in the following two years.
- In the case of transactions not met with the fair market price, failure to make the necessary adjustments leads to incorrect results in determining both the Adjusted Covered Taxes and the Net Qualifying Income and thus the ETR.
Why involve an expert?
Every GloBE taxpayer must submit a QDMTT advance return – in general rule by 20 November 2025, even if a safe harbour or exemption applies or no top-up tax is actually due. Failure to file, delay in filing, or incorrect filing may lead to a fine of up to HUF 10 million, so it isn’t worth waiting until the last moment to determine the possible exemption or calculate the QDMTT expected to be paid for the tax year.
If the safe-harbour, or permanent de minimis tests have not been performed yet, they should be completed immediately, as the exemption can avoid the top-up tax advance payment, and significantly reduce the administrative burden of the GloBE Information Return (GIR).
QDMTT/ETR mechanism significantly differs from the “classic” corporate income tax calculation. Aligning accounting (even according to multiple standards), tax, and transfer pricing data, handling covered-tax adjustments, and managing temporary differences require a complex tax and accounting approach. Even minor inattention can cause a serious risk, so it is worth involving an expert to ensure that the group fulfils its GloBE obligations on time and in accordance with the regulations.
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.
