QDMTT Advance Return – Deadline: 20 November 2025

1. Filing Obligation and Deadline

For constituent entities belonging to a group that prepares its consolidated financial statements on a calendar year basis, the qualified minimum domestic top-up tax (QDMTT) advance return for the 2024 tax year must be submitted to the Hungarian Tax Authority by 20 November 2025. Please note that filing the advance return is mandatory, even if the entity has no QDMTT liability, for example due to the application of exemptions or a nil tax base.

2. Form Status

The final official form of tax return has not yet been released, but it is likely to be published soon. Filing will be done via the ONYA platform, and a valid signatory rights or Power of Attorney is required (if PwC submits the return on behalf of the client).

3. Designation Rules

Based on the published draft tax return, similar to last year’s registration obligation (GLOBE Notification), it will be possible to designate one Hungarian constituent entity to submit the advance return on behalf of the group. It is important to highlight that there is currently legal uncertainty as to whether the method selected for fulfilling the QDMTT tax liability for a given fiscal year may be subsequently modified in the course of filing the final QDMTT return.

4. Final QDMTT Return and GIR

Current legislation suggests that a final QDMTT return will likely be required, with deadlines as follows:

• the end of the 15th month following the end of the tax year,
• the end of the 18th month following the end of the Transition Year, so for calendar year taxpayers the deadline for FY2024 is 30 June 2026.

This deadline coincides with the submission date of the GloBE Information Return (GIR), which is a standardised XML-based reporting format finalised by the OECD in 2023. The GIR must be submitted by the relevant multinational enterprise groups, and the data will be exchanged automatically between signatory jurisdictions under the framework of the Multilateral Competent Authority Agreement (MCAA). Hungary is going to join the MCAA as a signatory based on the government decree issued on 25 September, and the current autumn tax package draft provides the framework for its domestic implementation.

In parallel, the European Union has also established its own information exchange mechanism: the DAC9 directive aims to ensure that data reporting related to the global minimum tax is carried out in a harmonised and automatic manner across the EU.

PwC Hungary is prepared to assist with the QDMTT tax advance obligation, and can offer tailored services to your specific needs, including:

• We provide end-to-end assistance covering:
  • Assessment of the applicability of exemptions (Safe Harbours), including analysis and interpretation;
  • Preparation of QDMTT-calculations, determination of the advance payment amount;
  • Completion and submission of the QDMTT tax advance return. In this case, we will require a formal authorization from you valid in front of the Tax Authority. Please note that registration of this authorization with the tax authority may take time (approx. 1-2 weeks).
• Alternatively, we offer:
  • Review of calculations prepared by you;
  • Support limited to the completion of the tax return, based on the data and calculations you provide;
  • Support with both completion and electronic submission of the tax return.

Should you have any questions regarding this topic, please feel free to contact our experts: