Global Minimum Tax: Key Changes in the Hungarian Implementation – What Local Subsidiaries Need to Know

July 15, 2025 | Author: László Killik

In June 2025, the Hungarian Parliament passed the spring tax package, introducing several modifications that affect the domestic implementation of the global minimum tax (OECD Pillar II). The changes were published in Act LIV of 2025, in issue 73 of the Hungarian Gazette (Magyar Közlöny), and they align with the previously submitted bill without any substantial alterations.

The amendments target three main areas that are particularly relevant for Hungarian subsidiaries of international corporate groups.

  1. Extended deadline for GloBE information filing

From now on, the filing deadline for reporting obligations related to top-up tax liability has been extended:

  • The new due date is the last day of the second month following the end of the fiscal year,
  • For calendar year taxpayers, this means February 28 of the following year.

Previously, this deadline was the end of December. The amendment gives more time to collect the necessary information from:

  • the ultimate parent entity (UPE),
  • and any other Hungarian group entities subject to GloBE reporting.

Why it matters for Hungarian subsidiaries:

Even if your Hungarian entity is not responsible for preparing the consolidated GloBE return, you may still have obligations to submit or support local filings, making coordination with the group tax function essential.

  1. Extension of the default penalty scope

The act also extends the scope of the HUF 10 million (approx. €25,000) default penalty to apply in the following cases:

  • Incomplete, inaccurate or incorrect GloBE returns,
  • Failure to file required data reports related to the domestic top-up tax.

This amendment enters into force on the 31st day after publication: August 19, 2025.

Important transitional relief:

For tax years beginning before December 31, 2026, the penalty can be waived if the affected entity acted in line with what could reasonably be expected in the given situation.

  1. New accounting treatment: accruals required

From January 1, 2026, the Hungarian Accounting Act introduces a new rule:

  • The expected top-up tax liability must be recognized as deferred (accrued) income in the books for the current financial year.
  • This accrual must be reversed when the final tax is determined and reported.

What does this mean in practice?

Hungarian entities will need to:

  • Estimate their share of the global top-up tax before the GloBE calculation is finalized.
  • Document the assumptions and coordinate with the parent company’s finance and tax teams.
  • Ensure alignment with group-level reporting and audit expectations.

Summary

These changes aim to align Hungarian domestic rules with international standards under Pillar II, but they also introduce new compliance risks and additional administrative burdens for local subsidiaries. In particular, it is essential that Hungarian entities:

  • Establish strong collaboration with the group-level GloBE coordinators.
  • Build internal controls to support accurate reporting.
  • Understand both the tax and accounting implications of the local implementation.

If your group is affected by the global minimum tax and you want to ensure full compliance with the Hungarian rules, our experts are here to support you.