The Hungarian Tax Authority (HTA) has published the draft of the form on which domestic constituent entities subject to the qualified domestic top-up tax advance can declare their 2024 top-up tax advance.
Since domestic constituent entities falling under the global minimum tax rules – or the designated local entity acting on their behalf – are required to submit the advance tax return for the 2024 financial year by 20 November 2025, the lack of a published form had become an increasing concern as the deadline approached. Without the form, taxpayers could only speculate about the exact data they would need to provide.
With the publication of the form and the official filling instructions, domestic group members can now start preparing their advance tax returns with greater certainty. Advance payments can be made via bank transfer to the HTA’s top-up tax revenue accounts in Hungarian forints, euros, or US dollars.
The tax return must be submitted via the ONYA portal, in the same manner as the form for the global minimum tax registration obligation.
Currently, it appears that the scope of information required on the tax return is relatively limited. Constituent entities need to report the amount of qualified domestic top-up tax expected to be payable for the relevant tax year. However, this means that taxpayers who are not eligible for any safe harbors must complete the detailed calculations of the effective tax rate and top-up tax according to the general rules by 20 November.
At the same time, constituent entities who are exempt from paying qualified domestic top-up tax advance are required to declare the reason for their exemption. However, detailed provisions for the safe harbors are still unknown, as the Hungarian global minimum tax law delegates their specification to a ministerial decree. Until this decree is issued, taxpayers who may be eligible for any safe harbors still lack the necessary information to accurately complete their advance tax returns and must wait for the official guidance.