Support with Annual Compliance Obligations under the Global Minimum Tax Framework

The GloBE notification is not a one-off administrative requirement

The annual notification obligation relating to the global minimum tax should not be regarded as a one-off technical exercise. Each year, the affected Hungarian constituent entities must assess whether the group remains within the scope of the GloBE rules, which Hungarian entities are affected, which entity will submit the notification, and in what capacity the relevant company acts, either as an individual constituent entity or as the designated local entity.

The notification obligation may apply even where the Hungarian entity ultimately has no top-up tax liability, because the filing requirement is fundamentally linked to the group falling within the scope of the global minimum tax rules and to the entity’s status as a Hungarian constituent entity. Complete and accurate disclosure of both group-level and local information on the GLOBE notification form is therefore essential. This includes, among other matters, details of the ultimate parent entity, the Hungarian constituent entities, the designated local entity and the constituent entity responsible for GIR/DAC9 reporting.

Notification, tax returns and the GIR are interdependent obligations

Annual GloBE notifications cannot be managed in isolation from the subsequent tax prepayment return, QDMTT return and GIR/DAC9 reporting. The expanded 24GLBADO form published by the Hungarian National Tax and Customs Administration in 2026 also reflects these interdependencies, as the final settlement return takes account of certain data requirements of the GIR/DAC9 reporting framework.

Experience from the first live filing cycle indicates that the greatest risk is not simply missing a deadline. More commonly, the difficulty arises when constituent entity data, calculations, elections and safe harbour positions are only finalised shortly before the filing date.

Different priorities for Hungarian-headquartered groups and Hungarian subsidiaries

For multinational groups headquartered in Hungary, annual notifications form part of the group-wide GloBE compliance process. This requires coordination of the responsibilities of the Hungarian ultimate parent entity and the group’s Hungarian and foreign constituent entities.

For Hungarian subsidiaries of multinational groups, the focus is instead on the accurate identification of local obligations. Hungarian constituent entities must determine whether they have an independent notification or return-filing obligation, which entity should act as the designated local entity, what data must be provided to the ultimate parent entity, and which documentation supports the Hungarian GloBE position.

Accordingly, group-wide coordination is the principal priority for Hungarian-headquartered groups, while local compliance and reporting to the parent entity are generally the key considerations for Hungarian subsidiaries.

Support with annual GloBE compliance obligations: Andersen services

Andersen Hungary’s tax advisers can support affected businesses in the following areas:

• Assessing whether annual GloBE compliance obligations apply to the Hungarian constituent entities.
• Identifying the data, information and tasks required for notifications and tax returns.
• Preparing notifications and tax returns and supporting the submission process.

Further information on Andersen’s global minimum tax advisory services is available on this page.