global minimum tax advance payment

For the 2025 consolidated fiscal year corresponding to the calendar year, the qualified domestic top-up tax advance must be declared and paid by 20 November 2026 using form 25GLBADO. Where the consolidated fiscal year differs from the calendar year, the deadline is the 20th day of the eleventh month following the last day of the fiscal year.


1. Form 25GLBADO

Compared with the previous advance return filed using form 24GLBADO, additional information must be provided when completing the form for the 2025 fiscal year. This information includes, among others, the first and last day of the fiscal year according to the consolidated financial statements of the ultimate parent entity, the country code of the ultimate parent entity, the presentation currency of the consolidated financial statements, the financial accounting standard applied for the purposes of determining the QDMTT, and the currency of the related financial statements.

The return must include the details of the constituent entities, specify the constituent entity or entities liable for the payment obligation and, where an exemption or safe harbour is applied, indicate the relevant exemption category.

The return may be prepared in Hungarian forints, euros or US dollars. Where the advance return is prepared in a foreign currency, payment may be made either in the currency of the return or in Hungarian forints. Where the return is prepared in Hungarian forints, payment must also be made in Hungarian forints. In the advance return filed by the designated local entity, the advance payment liabilities of the constituent entities must be declared and paid in the same currency. The return must also be filed where the amount of tax payable is zero.

2. Exemptions and safe harbours

In relation to the qualified domestic top-up tax, the Minimum Tax Act provides  several exemptions and simplification methods, the detailed rules for which are set out in NGM Decree No. 38/2025 (XII. 19.).

Transitional CbCR Safe Harbours

The transitional CbCR Safe Harbour was originally introduced as a three-year transitional relief. Subsequent OECD guidance extended the application period by a further year. Accordingly, at international level, the relief may also be applied to fiscal years beginning on or before 31 December 2027 but ending no later than 30 June 2029. However, the applicability of the extended period in Hungary must be assessed on the basis of the Hungarian legislation in force at the relevant time.

Based on simplified calculations using data from the group’s CbC Report forming part of its transfer pricing documentation, the transitional safe harbours exempt companies from top-up tax. These are the de minimis test, the simplified effective tax rate test and the routine profits test.

  • De minimis test: The transitional CbCR Safe Harbour may be applied in respect of a jurisdiction if the total revenue of the constituent entities resident in that jurisdiction, as reported in the qualified CbC Report, is less than EUR 10 million and their profit or loss before income tax is less than EUR 1 million.
  • Simplified effective tax rate test (ETR): The safe harbour may be applied if the ratio of the jurisdiction’s simplified covered taxes to its profit before tax reported in the qualified CbC Report reaches 16% in the fiscal year beginning in 2025. Simplified covered taxes must be determined based on the current-year income tax expense reported in the qualified financial statements, including deferred tax expense.
  • Routine profits test: The routine profits test is met if the profit before tax reported in the CbCR for the relevant jurisdiction, determined after applying the adjustments required for that jurisdiction, does not exceed the substance-based income exclusion for that jurisdiction. Where the jurisdictional profit is zero or negative, the amount of the substance-based income exclusion does not need to be determined.

If a multinational enterprise group or large-scale domestic group does not apply the transitional CbCR Safe Harbour in a particular jurisdiction in an earlier fiscal year falling within the scope of the global minimum tax, it may not, as a general rule, elect to apply it in subsequent fiscal years, even if the conditions for the safe harbour are subsequently met. This is referred to as the “once out, always out” rule. However, the exceptions provided for by law must be assessed separately.

Other exemptions

De minimis exclusion: This exemption may be applied annually if the average qualified revenue of all constituent entities resident in Hungary is less than EUR 10 million and their average qualified income is negative or less than EUR 1 million. These indicators must be assessed based on the average of three fiscal years, namely the relevant fiscal year and the two preceding fiscal years.

Initial five-year exemption: The qualified domestic top-up tax payable in Hungary may be reduced to zero in the following cases:

  1. In the case of a multinational enterprise group, during the first five years of the initial phase of the group’s international activity, provided that the group has constituent entities in no more than six jurisdictions and the aggregate net book value of tangible assets recorded by all constituent entities in all jurisdictions other than the reference jurisdiction does not exceed EUR 50 million. A further condition is that the parent entity holding an ownership interest in the Hungarian constituent entity must not be subject to a qualified IIR, or the IIR top-up tax payable by that parent entity must also be reduced to zero.
  2. In the case of a large-scale domestic group, during the first five years beginning on the first day of the fiscal year in which the group first falls within the scope of the Minimum Tax Act.

Penalties and transitional penalty relief

Failure to comply with the filing obligation, or late, incomplete or incorrect filing, or filing containing false information, may result in a default penalty of up to HUF 10 million. However, according to the information published by the Hungarian tax authority, taxpayers acting in good faith and with due care are exempt from penalties in respect of fiscal years beginning before 31 December 2026.

It is important to note, however, that this relief does not apply in cases of fraud, abuse or tax avoidance, which remain subject to the full range of applicable penalties.