Hungary Issues GloBE Registration Form and Domestic Filing Entity Form

Section 44(1) of the GMT Law (Act LXXXIV of 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 (ie December 31, 2024 for the 2024 calendar tax year. In the case of  taxpayers not using the calendar year basis, the reporting deadline is the last day of the 12th month from the start day of the tax year beginning in 2024).

Section 31 of the Autumn Tax Package (Bill T/9724 on Amendments to Certain Tax Laws) 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. 

On November 15, 2024, the Hungarian Tax Authority issued the draft registration form.

Unlike the requirements in the Autumn Tax Package the draft registration form only requires data on the domestic constituent entities of multinational enterprise groups 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 for domestic constituent entities and the ultimate parent entity as either:

-Qualified domestic top-up tax
-Qualified IIR tax
-Qualified UTPR tax (from 2025)
-None of the above

The draft domestic filing entity form was also released. This permits a designated domestic entity 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 GMT Law. 

The registration form requires information on whether the reporting entity is reporting only on their own behalf or whether they are a designated domestic filing entity filing on behalf of all domestic group members. If the group member who is required to report fills out the registration form only for itself, it must declare the number of domestic group members of the corporate group for GloBE purposes.