Deadline and transitional rules

As a general rule, companies within the scope of the global minimum tax are required to file and pay the top-up tax within 15 months following the end of the tax year.

However, as 2024 qualifies as a transitional year, affected entities are granted an extended deadline of 18 months to comply with their obligations.

For taxpayers with a calendar financial year, the deadline is 30 June 2026.

By this date, the following obligations must be fulfilled:

• submission of the 24GLBADO return for the 2024 tax year, and
• where applicable, completion of the related data reporting via the NAV DCC API system (a technical data interface system of the Hungarian tax authority).

Scope of application

The rules apply to Hungarian members of corporate groups that:

• are part of a multinational or large domestic group, and
• have annual consolidated revenues of the ultimate parent entity reaching or exceeding EUR 750 million in at least two of the four tax years preceding the relevant tax year.

Key features of the 24GLBADO return

The purpose of the return is to provide the data necessary for determining the top-up tax (e.g. QDMTT, IIR).

Please note that:

• compared to advance tax filings, the return contains significantly more detailed information and requires not only tax calculation but also extensive data disclosure,
• the detailed rules and completion requirements are set out in Decree No. 4/2026 (I. 26.) of the Ministry for National Economy,
• the return must be submitted via the ONYA platform,
• submission is mandatory even in cases of exemption, with the appropriate legal basis indicated.

Reporting obligations (GIR / DAC9)

In practice, three main scenarios can be distinguished with respect to the reporting obligations under the global minimum tax regime. The system is designed to ensure that group entities do not need to submit a separate GloBE Information Return (GIR / Top-up Tax Information Return) in each jurisdiction; instead, information can be shared centrally through automatic exchange mechanisms.

1. Central filing within the EU (DAC9)

If the ultimate parent entity or a designated filing entity submits the GIR in an EU Member State, the data will be transmitted to the Hungarian tax authority via automatic exchange of information.

2. Central filing outside the EU

If the GIR is submitted in a non-EU jurisdiction, it must be assessed whether Hungary receives the relevant information through an effective and legally valid exchange of information framework with that jurisdiction.

3. Local reporting in Hungary

If there is no adequate information exchange mechanism between the filing jurisdiction and Hungary (i.e. no agreement ensuring the automatic exchange of the annual GIR), the exemption based on central filing cannot be applied. In such cases, Hungarian group entities may be subject to a separate local reporting obligation towards the Hungarian tax authority (NAV), to be fulfilled via the NAV DCC API system by 30 June 2026.

What is the NAV DCC API System?

The NAV DCC API is a technical data interface that enables companies to submit global minimum tax-related reports (GIR / DAC9) electronically in a structured (XML) format, potentially in an automated manner. The system is based on EU administrative cooperation rules (DAC) and supports secure data exchange between tax authorities.

Penalties and transitional relief

Please note that failure to comply with global minimum tax obligations — including failure to file returns or submit required data, or submitting incomplete, inaccurate, or incorrect information — may result in significant penalties.

• The Hungarian tax authority (NAV) may impose default penalties of up to HUF 10 million for non-compliance or incorrect reporting.
• Penalties may apply not only to failure to file but also to late or improperly completed submissions.

At the same time, as a transitional relief, for tax years starting before 31 December 2026, taxpayers acting in good faith and with due diligence may be exempt from penalties.

Penalty relief may apply in particular in cases of:

• factual errors,
• initial shortcomings due to first-time application,
• uncertainties in legal interpretation,
• or errors that do not result in tax advantage.

However, it is important to note that such relief does not apply in cases of fraud, abuse, or tax evasion, which remain subject to full penalties.