The legal framework for implementing tasks related to the global minimum tax (GloBE) is continuously evolving. In recent months, several implementing regulations have been published. The autumn tax package refined the conceptual framework of the global minimum tax and the rules on information exchange. These provisions must be applied when fulfilling the obligations due on 30 June 2026, and since the rules are quite complex, preparation should not be postponed.
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New implementing regulations on the Global Minimum Tax: the framework for the filing and reporting obligations due on June 30
The global minimum tax applies to corporate groups whose ultimate parent entity achieved or exceeded consolidated revenue of EUR 750 million in at least two of the preceding four tax years.
Detailed rules governing the CbCR safe harbour and GloBE exemptions
One of the regulations, which will enter into force on 19 January 2026, clarifies and specifies the exemption rules. It refines the definitions, the technical requirements, and also sets out the necessary disclosures and adjustment items. A significant number of companies are expected to make use of the exemptions in 2025 as well, and for them it may be important to become familiar with this regulation.
GIR data reporting: 30 June 2026
Another new regulation sets out the data content of the GloBE Information Return (GIR), which must be applied for the first time on 30 June, and which entered into force on 1 January 2026. The required data content is highly extensive: companies must disclose not only the structure of the corporate group and the details of its members, but also the jurisdictional elections available in the relevant state, the effective tax rate, covered taxes, recognised profit or loss, the substance-based income exclusion, and the detailed data used for calculating the top-up tax. As a result, tax authorities will obtain a uniform and comprehensive view of the corporate group’s GloBE position, meaning that the reporting obligation is far more than a mere formal requirement.
Exemption from filing the GIR
As a general rule, the GIR must be filed by the Hungarian group entity or by a local entity designated by it. However, the entity may be exempt from the reporting obligation if the GIR has already been filed by the ultimate parent entity or a designated group entity in a jurisdiction with which Hungary has a qualifying information exchange agreement. In such cases, the Hungarian taxpayer is only required to separately notify the Hungarian tax authority (NAV) of the identification details of the relevant group entity and the place of filing.
Preparing for the GIR
Complying with the GIR is not straightforward, not only because of the need for accurate data collection and calculations, but also due to the coordination of differing rules across the jurisdictions concerned. It is therefore advisable to clarify at group level as soon as possible who will be responsible for preparing the GIR report and to begin the actual work without delay, given the complexity of the required data and the slow flow of information within the corporate group.
Local top-up tax return (QDMTT): the deadline is also 30 June.
It is important to emphasize that the GIR is not identical to the QDMTT return, which must also be filed by 30 June 2026 by those entities that were already within the scope of the GloBE rules in 2024. The regulation governing the form and data content of the return was published on 26 January 2026; however, the filing form is not yet available. The application of the safe harbour does not exempt taxpayers from the filing obligation.
Why is it worth seeking expert assistance in fulfilling GloBE obligations?
Due to the complexity of the GloBE rules, the significant volume of related calculations and administrative burdens, the short preparation time, and the serious consequences of non-compliance, it is advisable for companies to consider engaging external experts.
Entrust the management of your GloBE obligations to the experts at LeitnerLeitner !
Don’t risk errors or delays: LeitnerLeitner’s team of tax advisors is ready to take on your GloBE reporting, filing, and planning tasks, whether they involve QDMTT calculations, IIR/UTPR obligations, or the practical application of related NGM regulations. Contact us today to ensure your corporate group complies with all Hungarian and international minimum tax requirements.
