GMT Amendments in the Hungarian Autumn Tax Package Passed to President for Signature

The Hungarian Autumn Tax Package (Bill T/9724 on Amendments to Certain Tax Laws) has been approved by Parliament and was sent to the President for signature on November 27, 2024. 

Sections 30-36 include amendments to the Global Minimum Tax Law (Act LXXXIV of 2023). 

Most notably these amendments expand on the registration and QDMTT declaration/payment requirements.

Registration

Section 44(1) of the GMT Law 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.

Section 31 of the Autumn Tax Package provides that the information to be provided will be:

-the identification information of the group members, including their value added tax number, intra-community VAT number (if any), the State in which they are resident and their classification under the Pillar 2 law

– information on the overall corporate structure of the multinational group or large domestic group, including the controlling stakes held by each group member in other group members.

QDMTT Returns/Payment

Article 44(2) of the GMT Law requires submission of an additional domestic tax return (a ‘DMT Top-Up Tax Return’) by the GIR filing deadline.

However, Section 32 of the 2024 Autumn Tax Package provides that for QDMTT purposes, the group member (or a designated filing entity) must submit an advance tax declaration and pay the QDMTT by the 20th day of the eleventh month following the last day of the relevant tax year. This applies for the first time in relation to the tax year starting in 2024.