In connection with the obligations related to the Global Minimum Tax (GloBE), the first domestic filing deadline is approaching. Companies whose financial year coincides with the calendar year must submit their domestic GloBE advance tax return for FY2024 by 20 November 2025. If a QDMTT top-up tax liability also arises, the corresponding amount must be paid as an advance tax payment by the same date, simultaneously with the submission of the return — this effectively represents a 100% tax top-up obligation.
GloBE: important filing deadline – Non-compliance may result in fines up to several million forints
For companies whose financial year corresponds to the calendar year (i.e. from 1 January 2024 to 31 December 2024), the deadline for submitting the domestic GloBE advance tax return under Hungarian regulations is 20 November 2025.
For taxpayers with a non-calendar financial year, the filing deadline for the domestic advance tax return for FY2024/2025 will be the 20th day of the 11th month following the end of the financial year.
During our GloBE webinar on 4 November 2025, we will share further details and practical insights regarding the global minimum tax obligations.
Why is the accurate completion of the GloBE tax advance return important?
Completing the GloBE return correctly is not merely an administrative formality — it also involves tax compliance risks.
While the HUF 10 million non-compliance penalty cannot be imposed if the taxpayer has acted with due care under the given circumstances, it is the taxpayer’s responsibility to credibly demonstrate this. Therefore, it is strongly recommended to ensure the accurate determination of all tax obligations.
What the GloBE tax advance return contains (24GLBADO form)
The National Tax and Customs Administration has published the referenced GloBE advance tax return form (“24GLBADO” return). On this 24GLBADO return, the following items must be indicated in addition to the information previously provided on the GloBE notification form:
- The amount of the calculated QDMTT advance, which must correspond to the QDMTT liability for FY2024;
- And the application of Safe Harbour or other exemptions for FY2024
Having the necessary calculations for the GloBE tax advance return is essential
However, it is not sufficient for a taxpayer to only now start assessing their potential global minimum tax position: to complete the GloBE advance tax return, the results of the following analyses and calculations should already have been included in the FY2024 Financial Statements. Their existence and execution are essential for the accurate and complete preparation of the GloBE advance tax return, in particular:
- Examination of the applicability of any temporary and permanent exemptions;
- If no exemption applies, calculation of the QDMTT for FY2024.
If a company falls under the Pillar II (global minimum tax) rules but the above analyses have not yet been completed, it is advisable to start them as soon as possible so that all necessary information is available by the filing deadline.
It should also be noted that in all cases, the calculations supporting the data reported in the domestic GloBE tax advance return must be documented, including situations where no top-up tax arises for FY2024, and therefore no advance payment obligation exists — whether due to the application of an exemption or because the effective tax rate reaches 15%.
Given that, in a potential tax audit, the tax authority typically requests documentation of these calculations as a first step, having proper documentation is especially important. If these calculations were prepared at the parent company level and the company does not have access to them, it is recommended to obtain them as soon as possible and review them according to Hungarian regulations.
What can affected companies do now? – Key actions step by step
- Involve tax and accounting leaders: Since GloBE obligations involve tax, accounting, and legal aspects, all three areas should be engaged in the process.
- Map group members and collect data: Gather information on consolidated revenue, subsidiaries, ultimate parent company, intermediate entities, and financial year data.
- Examine exemptions: Review Safe Harbour, de minimis, SBIE, domestic exclusions, and determine whether each group member is eligible.
- Prepare ETR calculations: Assess the Effective Tax Rate (ETR) in every jurisdiction where the group operates, especially in Hungary.
- Calculate top-up tax (QDMTT/IIR): If exemptions do not apply and the ETR does not meet the minimum rate, calculate the required top-up tax.
- Prepare return and data submission: Ensure that the 24GLBADO advance return (and prior GloBE notification) is completed and submitted on time, supported by accounting and documentation.
