GloBE Filings in 2026: What You Need to Know About the 30 June QDMTT and GIR Deadline

In Hungary, the global minimum tax rules apply to Hungarian constituent entities of multinational enterprise groups or large-scale domestic groups whose annual consolidated revenue reached EUR 750 million in at least two of the four fiscal years preceding the relevant fiscal year.

Hungarian group members will need to comply with several significant Pillar Two (GloBE) obligations in the coming period.

For calendar-year taxpayers, 30 June 2026 is a key deadline under the global minimum tax regime. By this date, the local QDMTT return for the 2024 fiscal year and, in certain cases, the GloBE Information Return, or GIR, must be filed. According to the completion guidelines issued by the Hungarian Tax Authority, calendar-year taxpayers must submit the information relating to the 2024 fiscal year by 30 June 2026.

The deadline therefore involves much more than a technical administrative task. A properly prepared return requires transparent calculations, a documented assessment of available exemptions and safe harbours, and group-level coordination of the relevant data.

30 June 2026: The Next GloBE Deadline for Calendar-Year Taxpayers

The first fiscal year affected by the global minimum tax in Hungary is 2024. A number of compliance obligations relating to the 2024 fiscal year have already had to be fulfilled, including the preliminary notification obligation and the QDMTT advance return and payment obligations.

However, the compliance tasks relating to 2024 have not been completed yet. Calendar-year taxpayers must therefore pay particular attention to two principal obligations due on 30 June 2026:

• the local QDMTT return; and
• the GIR filing or, in certain cases, the subsequent notification relating to the GIR.

Local QDMTT Return: Relevant Even Where No Top-Up Tax Is Payable

The deadline for filing the local QDMTT return is 30 June 2026 for calendar-year taxpayers.

Constituent entities for which an advance return was filed by 20 November 2025 are also required to submit a final domestic top-up tax return.

It is important to note that Hungarian constituent entities are not exempt from the filing obligation even where they are eligible for an exemption or Safe Harbour in respect of the 2024 fiscal year, such as the CbCR Safe Harbour. In other words, similarly to the advance return, the final local return must also be filed irrespective of whether an exemption or safe harbour applies.

The filing obligation therefore applies to every Hungarian entity that is a member of a multinational enterprise group or a large-scale domestic group falling within the scope of the global minimum tax rules for the 2024 fiscal year, regardless of whether any top-up tax liability arose in Hungary.

GIR Filing: Complex International Information Reporting

The GloBE Information Return is also due on 30 June 2026.

Unlike the local QDMTT return, the GIR is a complex information reporting package containing detailed information not only on Hungary but on every relevant jurisdiction. This includes, among others, information on effective tax rates, covered taxes and top-up taxes.

Another important difference compared with the local QDMTT return is that, in certain circumstances, a Hungarian constituent entity may be exempt from filing the GIR. This may be the case, for example, where the GIR is filed by the ultimate parent entity or another designated filing entity in a different jurisdiction.

In such cases, the Hungarian constituent entity may avoid filing the extensive and detailed GIR and will instead only be required to submit a brief notification to the Hungarian Tax Authority.

For the 2024 fiscal year, this notification must be submitted by 31 December 2026. The notification must identify where the GIR was filed within the group.

How Should Groups Prepare for the 30 June GloBE Obligations?

In practice, Hungarian constituent entities are less frequently designated as the entities responsible for filing the GIR. Most affected entities are therefore expected to prepare for the shorter GIR notification due in December.

Where a Hungarian constituent entity is responsible for filing the GIR on behalf of the group, extensive and time-consuming preparation will be required. In this case, the process is not merely a tax compliance project but also an international data and project management exercise.

In addition to a detailed understanding of the GloBE rules, successful compliance depends on the ability to obtain data from all foreign constituent entities of the group in a timely manner, in a consistent format and in a way that allows the information to be reviewed and verified. Due to the complexity of the filing form, particular attention is also likely to be required for XML validation.

QDMTT Return: Not as Simple as It May First Appear

Unlike the GIR, the local QDMTT return is considerably shorter and contains information relating exclusively to Hungarian constituent entities.

However, this does not mean that the return can be fully prepared within a few days. Although the form contains only a limited number of fields, our experience indicates that it may take several weeks to determine with certainty which box should be selected or what information should be entered in a particular field.

The challenge is therefore not the length of the return but ensuring that each item of reported information is properly supported in accordance with the Hungarian rules.

It is important to note that QDMTT calculations follow a jurisdictional approach. Accordingly, all Hungarian constituent entities must be taken into account together.

Deferred taxes and other specific adjustment items are also particularly important under the GloBE rules, as is the proper documentation of the relevant calculations. This is especially true where exemptions or safe harbours are applied, as the Hungarian tax authority may examine compliance with the relevant conditions in detail during a tax audit.

Proper documentation and transparent calculations are therefore of particular importance.

GloBE Review Considerations: What Should Be Checked Before 30 June?

Before the 30 June deadline, the affected Hungarian constituent entities should consider at least the following questions:

• Has it been properly determined for each Hungarian entity whether it qualifies as a domestic constituent entity?
• Where an entity is not treated as a domestic constituent entity, has the professional assessment supporting this conclusion been documented?
• Where a Safe Harbour is applied, have all relevant eligibility conditions been properly determinted?
• Are the calculations transparent, complete and verifiable?
• Are the calculations based on the correct underlying data?
• Do the calculations take all relevant adjustment items into account?
• Can the source of each amount be appropriately traced?
• Were the previous obligations, including the preliminary notification, advance return and advance payment, fulfilled by the relevant deadlines?
• Is all necessary accounting, tax and group-level documentation available?

RSM Expert Support for GloBE Filing Obligations

Under the global minimum tax regime, meeting the applicable deadlines is essential. However, it is equally important to ensure that the calculations, decisions concerning exemptions and safe harbours, and supporting documentation underlying the returns are properly substantiated.

RSM Hungary’s experts provide support in, among other areas:

• determining whether a group falls within the scope of the global minimum tax rules;
• identifying QDMTT and GIR obligations;
• assessing the availability of exemptions and Safe Harbour exemptions;
• preparing the relevant calculations; and
• supporting the filing and information-reporting processes.

Where your group is affected by the 30 June 2026 GloBE deadline, it is advisable to review the necessary data, calculations and documentation as soon as possible. This will help to ensure that the relevant filings are not only submitted on time but are also prepared on a professionally and properly supported basis.