Hungary changes global minimum tax reporting impacting in-scope MNEs

Within the framework of the “Autumn tax package”, Hungary’s parliament has implemented comprehensive legislative changes to global minimum taxation in the country. The changes streamline Pillar Two compliance and automatic information exchange between the participating jurisdictions.

Within the framework of the “Autumn tax package”, Hungary’s parliament has implemented comprehensive legislative changes to global minimum taxation in the country. The changes streamline Pillar Two compliance and automatic information exchange between the participating jurisdictions.

Single GloBE Information Return (GIR) for the whole EU – first filings due 30 June 2026

Hungary has implemented DAC9 (Council Directive (EU) 2025/872 of 14 April 2025 amending Directive 2011/16/EU on administrative cooperation in the field of taxation).

Under the newly implemented EU rules, in-scope multinational corporations (MNEs) will be able to file a single GloBE Information Return (GIR) each year in an EU member state. That GIR is then shared automatically with all other relevant EU tax authorities. Member states apply this framework from 1 January 2026, so the centralised system first applies to GIRs due by 30 June 2026. In practice, if your group files the GIR in any EU country under the centralised approach, the Hungarian tax authority will obtain the GIR via automatic exchange.

Centralised data reporting is coming for MNEs with members located outside of the EU

Ultimate parent entities or the designated filing members of MNEs that are active outside the EU can also file a single data report in one jurisdiction for the whole group following the publication of the Multilateral Competent Authority Agreement between competent authorities on the exchange of information relating to the global minimum tax, currently pending before the Hungarian parliament.

The agreement is a “qualifying competent authority agreement” within the framework of the Hungarian global minimum tax act, allowing MNEs with non-EU members to submit their data reporting in one implementing jurisdiction only.

Based on the OECD-approved “Dissemination Approach”, the agreement enables automatic exchange of data between Hungary and participating non‑EU jurisdictions such as Great Britain, Canada, Japan or the Republic of Korea.

Hungarian advance GMT return obligation stays in place with deadline of 20 November 2025

The centralised GIR regime does not affect the Hungarian advance top‑up tax compliance cycle already running for 2025. Hungarian entities – with a financial year aligned with the calendar year – must still meet the advance return and any advance payment obligations by 20 November 2025 (i.e. the 20th day of the 11th month following the balance sheet date).

The advance return must be filed even if no advance payment is due.

The Hungarian tax authority may already impose default penalties in relation to supplementary taxes ensuring a global minimum tax level in the following situations:

• for failure to comply with or late compliance with reporting obligations: a penalty of HUF 5 million (EUR 13,000);
• failure to comply with or late, incomplete, incorrect or false compliance with data provision, tax return and tax advance return obligations: HUF 10 million (EUR 26,000).

As a grace period, no penalty should be imposed for tax years before 31 December 2026 if the group member acted as may be expected in the given situation.

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