Hungary Proposes to Extend Pillar 2 Registration Deadline in 2025 Spring Tax Package

Section 44(1) of the Hungarian Pillar 2 law (Act LXXXIV of 2023 of November 30, 2023) provides that a Hungarian entity within the scope of the GloBE rules (or a designated domestic entity acting on its behalf)  is required to notify the tax authority within 12 months from the beginning of the tax year concerned.

On May 13, 2025, Hungary issued Bill T/11920 as part of the 2025 Spring Tax Package. 

Section 20 of Bill T/11920 proposes to amend the registration deadline to the last day of the second month following the last day of the tax year.

Note that in December 2024, the Hungarian Tax Authority issued Updated Instructions for the submission of the registration forms. They can now be submitted via ONYA (Online Nyomtatványkitöltő Alkalmazás) e-services portal of the Hungarian Tax Authority Website.

The registration form requires data on the domestic constituent entities of MNE or large-scale domestic groups and their ultimate parent entities.

In addition, the registration form requires the type of top-up tax liability to be chosen as either:

-Qualified domestic top-up tax

-Qualified IIR tax

-Qualified UTPR tax (from 2025)

-None of the above

The domestic filing entity form has also been released. This permits a domestic entity to be designated to file the registration form (and other GloBE tax returns) on behalf of other domestic members of the MNE/domestic group. In this case, a single registration form is be submitted for all domestic group members under Section 3(47) of the law.