The global minimum tax (GloBE) is the second pillar of the OECD’s international tax reform, which sets a minimum level of income tax for multinational enterprise groups. The organization began working on the relevant regulations in 2019. Initially, the focus was on creating a unified solution for the international taxation of digital services and big tech companies. This was later extended to include all groups with total revenue exceeding a certain threshold.

Implementation of the global minimum tax (GloBE) rules

In December 2022, EU Member States agreed to adopt the Pillar Two of the OECD tax reform as a directive, which establishes the global minimum tax rules (known internationally as GloBE) for multinational enterprise (MNE) groups and large-scale domestic groups in the EU. The directive (EU 2022/2523) mandates the application of GloBE rules for years beginning after 31 December 2023, and requires Member States to transpose the new regulations into their national laws by 31 December 2023.

On 31 October 2023, the Hungarian government presented bill no. T/5877 to the Hungarian Parliament, which, as part of the autumn tax package, included the proposed legislation on top-up taxes to ensure compliance with the global minimum tax rules. In accordance with the EU directive, this legislation took effect on 31 December 2023.

How can Andersen in Hungary assist you regarding GloBE?

The expert team at Andersen in Hungary provides support to businesses affected by the global minimum tax through the following services:

• Identification of the group under the GloBE rules for MNE groups with a Hungarian ultimate parent entity and conducting GloBE impact analysis
• Determination of the potential GloBE position of Hungarian constituent entities
• Assessment of the applicability of various exemptions
• Calculation of the jurisdictional effective tax rate
• Providing tax advisory services on GloBE-specific matters