Hungary Issues the Draft Advance QDMTT Return

On October 15, 2025, Hungary issued the draft Advance QDMTT Tax Declaration (Form 24GLBADO) as well as filing instructions and a draft XML guide.

Article 44(2) of the Minimum Tax 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. For the 2024 fiscal year this must therefore be submitted by November 20, 2025.

The Draft Advance QDMTT Return is a high-level form that requires information on the UPE, the total QDMTT payable, an allocation of the QDMTT for each group entity, as well as information on any exemptions that may apply (eg the de minimis election, CbCR Safe Harbour and initial phase of international activity exemption).

One local group entity can be designated to pay the tax and file the return under Article 44(2). Note that under Article 11(13) of the law a group of companies with a QDMTT liability may choose annually to:

-allocate the QDMTT among the group members based on GloBE income or the excess profit (as a proportion of the group members GloBE income/excess profit over the total group amount in the jurisdiction) in which the parent company has a 100 per cent shareholding, or

-the QDMTT determined for all domestic group members can be paid by a designated group member.

This is also required to be disclosed in the Draft Advance QDMTT Return.

The final return is to be available for filing soon on the ONYA e-filing service.