New rules apply to GloBe’s June 30 obligations – don’t wait any longer to prepare!

One ​​of the implementing decrees clarifies the rules of tax exemptions, provides guidance for the detailed calculation methodology of the exemptions, the underlying statements and adjusting entries. Since, based on the experience of the 2024 local supplementary tax advance returns (QDMTT), a large part of taxpayers subject to the GloBE were able to use the so-called CbCR safe harbor rules, i.e. temporary exemptions based on country-by-country reporting, many are expected to take advantage of the now clarified exemption rules in 2025. However, it is important to know that anyone who has not chosen the safe harbor exemption once cannot change it later, even if they meet the conditions.

The deadline for submitting the local supplementary tax return (QDMTT) is June 30, 2026 – for those who were already subject to GloBe in 2024. The form and expected data content of this is determined by another regulation, but in addition, in order to prepare the QDMTT return, a thorough knowledge of the regulation on the previously mentioned exemptions is also required. It is very important to emphasize that the enforcement of safe harbor exemptions does not exempt you from the obligation to file a return. 

In addition to all this, the GloBE information return (GloBE Information Return), also known as the GIR return for short, will be launched in parallel, which must also be submitted for the first time on June 30, 2026, now based on the results of the 2024 tax year. The data content of the report is extremely complex – which is dealt with in a third regulation: it must present the structure of the multinational corporate group, the options available in the countries concerned, the effective tax rate, the taxes covered, the recognized profit or loss, the profit exclusion based on economic presence, as well as the data and correction items necessary for calculating the additional tax. This gives the tax authorities a comprehensive, uniform picture of the global minimum tax position of the corporate group, meaning that the provision of data is not a mere formal obligation.  

The submission of the GIR is the obligation of the domestic group member, but if the ultimate parent company or designated group member submits it in another state with which Hungary has a recognized regulatory information exchange agreement, then the Hungarian subsidiary is not exempt from the reporting obligation. However, this is simpler in such cases, because only the data of the group member fulfilling the obligation and the country of submission need to be reported. 

“Understanding and fulfilling the overlapping GloBE reporting obligations is far from easy, the complexity of the domestic and international background rules and the continuous development of the detailed rules make practical application challenging. The situation can be even more complicated if several companies belonging to the given group operate in Hungary.”

– emphasized Péter Balázs, tax manager at LeitnerLeitner, GloBE expert. That is why the affected companies must immediately review the new legislation, clarify within the group which group member will be responsible for providing data, and start compiling the report. Although there are still almost 3 months until submission, it is not too early to start preparing, because the flow of data within multinational groups is often slow.

“Preparation started on time not only helps with administrative compliance, but also in mitigating later risks.