The legal framework for implementing Global Minimum Tax (GloBe) requirements is constantly evolving. Several implementing regulations have been published in recent months. The fall tax package clarified the conceptual framework of the global minimum tax and the rules for information exchange. These must be applied when fulfilling the obligations due on June 30, 2026, and since the rules are quite complex, preparations should not be delayed.
.png "Don’t wait until the last minute to meet your GloBe filing and reporting obligations by June 30")
New implementing regulations for the global minimum tax: background on the reporting obligations for the June 30 filing
The global minimum tax applies to corporate groups whose ultimate parent company has achieved or exceeded consolidated revenue of €750 million in at least two of the preceding four tax years.
Detailed Rules for the CBCR Safe Harbor and GLOBE Exemptions
One of the regulations, set to take effect on January 19, 2026, clarifies and details the exemption rules. It defines the terms and technical requirements, and specifies the necessary disclosures and adjustments. Many companies are expected to take advantage of the exemptions in 2025 as well, so it may be important for them to familiarize themselves with this regulation.
GIR Reporting: June 30, 2026
The other new regulation sets forth the data requirements for the GloBE Information Return (GIR), which is applicable for the first time on June 30, and entered into force on January 1, 2026. The required data content is quite extensive: not only must the structure of the corporate group and the details of its members be disclosed, but also the options available in the given country, the effective tax rate, taxes accounted for, recognized profit/loss, profit exclusion deductible based on economic presence, as well as detailed data on the calculation of the supplementary tax. This provides tax authorities with a consistent and detailed picture of the corporate group’s GloBe position, meaning that the reporting is not merely a formal requirement.
Exemption from Filing the GIR
As a general rule, the GIR must be filed by the Hungarian group member—or a local entity designated by it. However, it may be exempt from reporting if the report has already been submitted by the ultimate parent company or a designated group member in a country with which Hungary has a recognized information exchange agreement. In such cases, the Hungarian taxpayer need only separately report the identifying information of the relevant group member and the place of submission to the NAV.
Preparing for the GIR
Compliance with the GIR is not straightforward: not only because of the need for accurate data collection and calculations, but also because of the need to harmonize the differing regulations of the countries involved. It is therefore advisable to clarify as soon as possible at the group level who will be responsible for preparing the GIR report and to begin the actual work, given the complexity of the data content and the slow flow of data within the corporate group.
Local supplementary tax return (QDMTT): the deadline is also June 30.
It is important to note that the GIR is not the same as the QDMTT return, which must also be filed by June 30, 2026, by those who were already subject to GloBe in 2024. The regulation regarding the form and data content of the return was published on January 26, 2026, but the return form is not yet available. The application of the safe harbor does not exempt entities from the reporting obligation.
Why should you seek expert assistance to meet GloBe requirements?
Given the complexity of the GloBe rules, the significant calculations and administrative burdens associated with them, the short preparation time, and the serious consequences of non-compliance, it is advisable for companies to consider engaging an external expert.
Let the experts at LeitnerLeitner handle your GloBE obligations!
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.
