The first global minimum tax notification obligation is finally here

Although the first global minimum tax return is still a long way off for those affected, an important task is here to complete even before the year ends.

Namely, taxpayers subject to the QDMTT (Qualified Domestic Minimum Top-up Tax), the local implementation of the global minimum tax, must declare that the group members are subject to the GloBe supplementary tax, they must present the multinational corporate group or large domestic group to which they belong, and they must even provide data on tax calculations. The deadline for this is December 31st before the end of this year respective the 2024 financial and tax year.

Within the Globe reporting obligation, the Hungarian domestic group member or its representative must indicate the data and classification of the group members, as well as the share of the supplementary tax that can be assigned to them, in addition to the structure of the corporate group. The designated representative acts on behalf of all domestic group members.

At the beginning of this year, the domestic legislation regulating the global minimum tax came into force in Hungary, the subjects of which are members of multinational corporate groups or large domestic corporate groups, where the consolidated annual revenue of the ultimate parent company reaches or exceeds EUR 750 million in at least two of the four tax years immediately preceding the tax year, meaning that taxpayers who typically file CbCR must also expect additional burdens arising from the GloBe.

Globe notification/reporting obligations – in addition to the “normel” QDMTT tax return – will later have to be repeated annually. In addition, since it is not certain that a similar reporting obligation also exists in the country of the parent company, as not all countries use this regulation, domestic group members must pay special attention to this in order to avoid later sanctions.

At LeitnerLeitner, a specialized team is at your assistance in full-scope advisory and assistance also regarding the global minimum tax.