Tax News - Data Reporting Obligation Related to Global Minimum Tax

Entities Subject to the Global Minimum Tax

The global minimum tax applies to multinational corporate groups whose revenue reaches or exceeds EUR 750 million in at least two of the four fiscal years preceding the relevant tax year. Companies subject to this regulation are required to report their supplementary taxpayer status in Hungary.

GLOBE Data Reporting

The GLOBE ("Global anti-Base Erosion") report must be submitted annually to the National Tax and Customs Authority within 12 months from the start date of the tax year subject to the supplementary tax obligation. Accordingly, Hungarian group members must submit the required data for the 2024 tax year by December 31, 2024, using the GLOBE data form available in the Online Form Filling Application (ONYA).

The data form requires various identifying information about the group members and the ultimate parent entity (UPE). Group members may agree among themselves that one designated entity will submit the report on behalf of all domestic group members, including their identifying data on the form. In this case, the other domestic group members are not required to submit separate reports.

If the group member obligated to report completes the form only for itself, it must declare the number of domestic group members subject to the supplementary tax obligation. Additionally, it may choose to indicate whether it will provide data reporting or submit a supplementary tax return for the reporting period. This latter declaration is optional.

Please note that during the data reporting process, it is not necessary to provide quantitative data related to the activities of the group member, nor to perform any calculations in order to determine the global minimum tax. The purpose of the data report is solely to inform the tax authority that the respective group member belongs to a corporate group subject to the global minimum tax regulations. The data report does not imply that the reporting group member will be required to pay the global minimum tax, as this depends on several additional conditions.

We also draw your attention to the fact that companies that do not meet the group-level revenue criteria set forth in the global minimum tax law and are therefore not subject to the minimum tax regulations are not required to submit a negative declaration or any related data report.

Penalty for failure to report

Failure to fulfill the reporting obligation may result in the tax authority imposing a penalty of up to HUF 5 million, unless the group member can demonstrate that it acted as reasonably expected under the given circumstances.