The Global Minimum Tax registration deadline (31 December 2024) is here!
What are the main takeaways?

From 2024 Global Minimum Tax (GloBE) has been introduced. This means that the global minimum tax is payable primarily in cases where the effective tax rate of a multinational group of companies in a given country is below the 15% minimum rate.

The global minimum tax is applicable for multinational groups with consolidated sales revenue exceeding € 750 million (approximately HUF 286 billion), i.e., the group of companies concerned is the same as the multinational groups that are subject to Country-by-Country Reporting (CbCR).

Companies must register with the Tax Authority using a HTA (Hungarian Tax Authority) form by 31 December 2024. Please note that groups of companies that apply the temporary country-by-country reporting ("CbCR") exemption with respect to Hungary are not exempt from the registration obligation, so a domestic group member subject to the Minimum Tax Act or a designated local entity acting on its behalf must comply with this obligation.

Although the HTA form is currently not available, the draft autumn tax package of 2024 set guideline its data content. Accordingly, the following data should be included in the document:

• Identification details of group members (e.g., tax number, EU tax number, the state in which they are resident),
• Classification of the group members under the Minimum Tax Act.
• Information regarding the general corporate structure.

Please note that the qualification of the group members under the Minimum Tax Act requires considerations from a global minimum tax point of view, so the involvement of a tax advisor seems necessary at this point

We highlight that with the release of the form for the registration, it should be further analyzed the exact data which should be submitted for the Hungarian authorities.

For your convenience, we have summarized the upcoming deadlines which should be noted.

In the case of a Globe obligated group member fails to comply with its statutory obligation, the Hungarian authorities may impose default penalty for the non-compliance in the following amounts:

• Non-compliance in the case of the registration obligation: HUF 5,000,000;

• Non-compliance in the case of the submission of the data report: HUF 10,000,000;
• If the taxpayer fails to pay at least 90 % of the tax expected for the tax year by the time limit, also considering the tax advance paid in the course of the tax year, the default penalty amounting up to 10 % of the difference between the tax advance paid and 90 % of the tax for the tax year shall be imposed upon him. (No late payment penalty, tax penalty or default penalty may be applied to the advance payment if the group member acted in good faith.)

Should you have any questions regarding the global minimum tax obligation, please do not hesitate to contact our professionals.

This newsletter provides general information and does not constitute tax advice.

WTS Klient is organising a conference on 4 December 2024 on this topic,
and is looking forward to welcoming representatives of interested companies.

The SAVE THE DATE for the event is published below:

Dear Partner,

Join us for the

Global Minimum Tax Conference at WTS Klient

(Stefánia Park Office Building, 1143 Budapest, Stefánia út 101-103)

on 4 December 2024, from 3 p.m. to 6 p.m.,

where we will shed light on the introduction of the Pillar Two global and Hungarian tax framework — an area with high complexity. Our conference aims to clarify the fundamentals, implications, and practical steps for adopting to the Pillar Two framework, offering essential insights for businesses in Hungary navigating these recent changes. We will also cover the draft bill recently presented to the Hungarian Parliament about the modifications of tax legislation for 2025, affecting the Pillar Two rules as well.

We have invited among others Hungarian and German tax professionals from the WTS network, leading lawyers of WTS Legal and an expert from the Hungarian Ministry of Finance, who will present his opinion on the issues raised from a legislative perspective.

We will contact you with the details later. In the meantime, please save the date in your calendar. To help us provide you with more useful information on this topic at the conference and beyond, please fill in our Pillar Two questionnaire by clicking on the link below.

The event is free, but registration is required. Please contact Esther Lausek at esther.lausek@wtsklient.hu to register.
Registration deadline is 27 November 2024. You will be notified by email when your registration is accepted.