Upcoming global minimum tax deadline: the 2024 tax return is now available, but preparation is also required for DAC9 reporting
30 June 2026 is a key deadline for Hungarian members of corporate groups that are subject to the global minimum tax and have a financial year corresponding to the calendar year. By this date, the annual top-up tax returnfor the 2024 tax year must be filed, and, where applicable, the DAC9 reporting related to the top-up tax must also be completed.
On 29 May, the Hungarian Tax and Customs Administration (NAV) made the extended 24GLBADO formavailable in the Online Form Completion Application (ONYA). The form now serves not only for reporting the 2024 qualified domestic minimum top-up tax advance, but also for filing the 2024 top-up tax return. The 24GLBADO form is available exclusively in ONYA. At the same time, it is important to note that the 24GLBADO annual tax return is not suitable for completing the DAC9 reporting obligation.
What must be completed by 30 June 2026?
The 2024 tax year qualifies as a transitional year under the global minimum tax rules. Therefore, instead of the general 15-month deadline, 18 months are available for filing the top-up tax return and the DAC9 report. For a tax year corresponding to the calendar year, the deadlinefor the 30 June 2026
The two obligations serve different purposes. The 24GLBADO form is used to report the Hungarian top-up tax liability or exemption, while full DAC9 reporting can only be submitted through DACentral, is an information reporting obligation prescribed under the global minimum tax framework, which may include broader group-level, jurisdictional and calculation data.
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What is the extended 24GLBADO return used for?
The extended 24GLBADO is the central Hungarian form for reporting obligations related to the global minimum tax. The form is available through ONYA and is used, on the one hand, to report the qualified domestic minimum top-up tax advanceand, on the other hand, to report the actual annual top-up tax liability for the 2024 tax year. In the latter respect, the return is suitable for reporting annual tax liabilities related both to the qualified domestic minimum top-up tax (QDMTT)and to the Income Inclusion Rule (IIR) .
The return must include not only the amounts of the tax advance and the final top-up tax, but also the basic data of the relevant corporate group.Among other things, the ultimate parent entity or entities, the domestic constituent entitiesand, where there are several Hungarian entities concerned, the data on the tax amounts allocated to each domestic constituent entity must also be indicated.
In relation to both the advance payment and the annual tax liability, the 24GLBADO form allows taxpayers to indicate the exemptions, elections and special legal grounds applied. These may include, for example, transitional or permanent safe harbour rules, the de minimis exclusion, and other GloBE rules that affect the tax payment obligation.
When developing the content of the form, NAV already took into account the content of the DAC9 reporting obligation. Therefore, the data included in the 24GLBADO return must be consistent with the group-level GloBE calculations and any DAC9 reporting. However, this does not mean that filing the 24GLBADO return replaces DAC9 reporting.
Download our free summary on which jurisdictions may qualify for an exemption from DAC9 reporting obligations in Hungary!
Why is DAC9 reporting a separate issue?
Under the global minimum tax rules, a domestic constituent entity, or a designated local entity acting on its behalf, is generally required to submit not only a tax return but also reporting related to the top-up tax to NAV. However, an exemption from the local reporting obligation is possible, if the DAC9 report is filed by the ultimate parent entity or a designated constituent entity in a jurisdiction that has a qualifying competent authority agreementin place with Hungary for the tax year concerned..
Within the European Union, this framework is provided by the DAC9 Directive. The Council of the European Union adopted the DAC9 Directive on 14 April 2025, which requires the automatic exchange of GloBE reports between Member States. On this basis, appropriate DAC9 reporting completed in an EU Member State may, as a general rule, exempt the Hungarian domestic constituent entity from filing the full report in Hungary .
For non-EU jurisdictions, the GIR MCAA, i.e. the Multilateral Competent Authority Agreement on the Exchange of GloBE Information, may be relevant. Hungary promulgated this agreement by Act XC of 2025. It is important, however, that the promulgation of the agreement and the statutory list of the jurisdictions concerned are not necessarily sufficient in themselves for the Hungarian exemption to apply. Under the GIR MCAA, the information exchange relationship must be bilaterally activated:both the sending and the receiving competent authority must submit the required notification to the Secretariat of the OECD Coordinating Body.
The list of active bilateral relationships is published on the OECD website and is updated on an ongoing basis. Therefore, in each case it must be checked separately,whether an active GloBE information exchange relationship actually exists for the relevant tax year between Hungary and the jurisdiction of the ultimate parent entity or the designated filing constituent entity. OECD exchange relationships list
The exemption of the Hungarian constituent entity is therefore not automatic. It must be examined separately whether there is a central, group-level filing - for example in the jurisdiction of the ultimate parent entity - that replaces the local Hungarian DAC9 reporting under the Hungarian rules. If there is no such reporting, or if Hungary does not have an active information exchange relationship with the jurisdiction of filing for the relevant tax year, the Hungarian domestic constituent entity or the designated local entity must prepare to complete the full DAC9 reporting in Hungary.
Download our free summary on the jurisdictions where, based on currently available data, DAC9 reporting may give rise to an exemption from the Hungarian reporting obligation for the 2024 tax year
What is currently known about the practical completion of DAC9 reporting?
In our previous blog post, we already presented the background and structure of DAC9 reporting .
Based on NAV's latest information, the submission of DAC9 reporting is no longer an open question: the obligation may be fulfilled exclusively through the DACentral system, in XML format.Accordingly, no ONYA or ÁNYK form that can be completed manually is expected for the full DAC9 reporting obligation. DAC9 reporting information notice
According to NAV's information notice, DAC9 reporting can be submitted through the DACentral unified data exchange platform. Based on the published DCC API technical documentation and test environment, the submission is based on the OECD GloBE Information Return XML schema. In order to complete Hungarian local reporting, the data detailed in NGM Decree 46/2025 (XII. 23.) must be prepared in an XML file in accordance with the OECD GIR XML schema and then submitted through the DACentral system.
From a practical perspective, the groups concerned should therefore clarify in good time who can prepare the required XML file, who will carry out the technical submission, and whether the necessary DACentral/API authorisations are available.
Open question: how should it be reported if DAC9 reporting is completed abroad?
The legislation prescribes a separate obligation where the Hungarian constituent entity is exempt from local reporting because the reporting is completed by another group entity, such as the ultimate parent entity or a designated filing constituent entity. In this case, the domestic constituent entity or the designated local entity must provide data to NAV within six months of the submission of the report:
- the identification data of the constituent entity that has completed or has been designated to complete the reporting;and
- the jurisdiction of filing..
In February 2026, NAV amended the GLOBE notification form and introduced new mandatory fields for the name, tax number and jurisdiction-of-residence country code of the constituent entity completing GIR/DAC9 reporting. However, it is currently not clear exactly which form will be used to complete the full notification required by law, particularly with respect to the data on the 'jurisdiction of filing'..
Why is it worth consulting an expert?
The availability of the extended 24GLBADO return is an important milestone in the Hungarian application of the global minimum tax, but it does not mean that all obligations for the 2024 tax year can be fulfilled with a single ONYA return.
Hungarian constituent entities must examine their annual top-up tax return obligation and their DAC9 information reporting obligation separately. The 24GLBADO form is used for the Hungarian annual tax return, while, based on NAV's latest information, full DAC9 reporting can only be submitted through DACentral, in XML format..
Special attention should be paid to whether whether the DAC9 reporting completed by the ultimate parent entity or another designated constituent entity replaces the Hungarian local reporting obligation.Even if it does, a subsequent Hungarian notification obligation remains in respect of the identification data of the reporting constituent entity and the jurisdiction of filing. The exact technical method of completing this obligation is currently not yet known.
Preparing for the 30 June deadline is therefore not only a tax advisory task, but also a data collection, group-level coordination and technical task. The groups concerned should clarify as soon as possible who will complete the DAC9 reporting, in which jurisdiction, whether the technical background required for submission through DACentral is available, and what evidence can be used to document compliance with the Hungarian rules.
Do you need support with the practical application of global minimum tax rules?
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Author: József Vizer
Managing Director, Lead Consultant, ICT Business Advisory Ltd.
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