The companies concerned will have to include in their accounts by the end of May the global minimum tax, if any, in addition to corporation tax. They must also have completed their assessment of the possibilities for exemption from the global minimum tax by then. The introduction of the new tax will also bring significant changes for multinational groups and their domestic affiliates. The precise application of the detailed rules will require the assistance of an experienced tax expert.
The global minimum tax is one of the solutions developed by the Organisation for Economic Co-operation and Development (OECD) to combat aggressive tax planning and is a uniform minimum profit tax of 15 percent for multinational groups and large domestic groups, wherever they operate. The purpose of paying additional tax at the minimum level is to discourage tax avoidance practices and to encourage groups to pay tax where their real economic activities are carried out.
"The regulation will affect groups of companies where the annual revenue as reported in the consolidated financial statements of the ultimate parent company reaches €750 million (in the order of HUF 286 billion) in at least 2 of the 4 years preceding the tax year." - explained tax expert József Vizer, the ICT Europe Group head of advisory.
"As a general rule, a group of companies comprises those entities that are linked by ownership or control in such a way that consolidated financial statements are prepared by the ultimate parent company. Important exceptions to the rule are certain excluded entities, such as state-owned enterprises, non-profit organisations, pension funds, investment funds. These entities are not subject to the global minimum tax but may be included if it is more beneficial for the group. In addition, a temporary or permanent exemption may apply to the whole or part of a group of companies, subject to certain conditions." - added József Vizer.
The expert stressed that if companies cannot meet any of the exemption criteria, the additional tax must be calculated and paid.
Important deadlines and obligations
The administrative obligations for the global minimum tax are linked to several deadlines, the closest of which for businesses with a normal financial year is the end of May for the preparation of annual accounts.
"It can be a headache for companies to include information on the recognised domestic additional tax in their annual accounts, because in many cases the exemption or tax liability can only be estimated at this stage. Indeed, many of the exemptions are linked to the so-called Country-by-Country Reporting (CbCR) data, which will most likely only be available by the end of the year. However, experts are clear that the mandatory notes to the annual accounts should also include the derivation of the global minimum tax: the tax liability or exemption, if any, and other references." - said the ICT expert.
József Vizer also mentioned among the global minimum tax deadlines linked to the normal financial year
- the deadline for declaring tax liability, which had to be 31 December 2024,
- the deadline of 30 June 2026 for the submission of the annual tax return and the payment of the additional tax,
- and the deadline for the declaration and payment of the recognised domestic additional tax advance, which is 20 November 2025 - a.
"The November deadline can be particularly problematic for companies, as in many cases the data needed for accurate calculations are still not available. The calculation of the additional tax advance may therefore be based on estimates, which poses a serious challenge for financial planning and compliance obligations." - stressed the head of advisory.
Numerous possibilities for error
Turnover rose global minimum tax rules are voluminous. In addition to national legislation, the European Union Directive and the OECD Directive, commentaries and guidance documents must also be taken into account.
"In the context of the calculations, the law refers to several ministerial decrees that have not yet been issued or published.. In their absence, the OECD Commentaries and Guidance Notes must be relied upon, which contain a number of detailed rules that are difficult for less experienced and less knowledgeable professionals to find and therefore not applied in calculations." - stressed the tax expert of the ICT Europe Group.
At the same time, the NAV may impose a default fine of HUF 5 million for failure to file a return or for late filing, or for filing a return that is late, incomplete, incorrect or contains untrue data, and a default fine of HUF 10 million for failure to file a return. In the event of a tax audit, the tax penalty may be 50% of the tax deficit established.
It is therefore advisable to prepare for the global minimum tax procedures in good time and to seek expert advice to help you make strategic decisions, reduce risks and optimise your tax optimisation!
