Global Minimum Tax - Prepayment Return
Global Minimum Tax - Prepayment Return
The Hungarian National Tax and Customs Administration (“NAV”) has recently published the final version of the Hungarian Top-Up Tax (QDMTT) Prepayment Return on the Online Form Filling Application (“ONYA”) platform in relation to the Global Minimum Tax. Please note that the final version differs from the previously released draft only in terms of its technical completion logic - there have been no substantive changes to its content.
We would like to draw your attention to the upcoming filing deadline: for MNE group members with a balance sheet date matching the calendar year, the due date for submission of the Prepayment Return is 20 November 2025.
Below, we provide a brief overview of the key elements required for completing the final version of the declaration.
The Prepayment Return should include detailed information regarding both the MNE group members and the amount of the tax advance payment. In particular, it should contain the identification data of the Hungarian group members and the ultimate parent entity, as well as the total amount of the recognized Hungarian Top-Up Tax advance payable by the group. The prepayment must be reported separately by currency – HUF, EUR, or USD – indicating the number of group members applying each currency. In addition, the declaration should specify the amount of advance attributable to each group member in the applicable currency, along with statements regarding the allocation of the Top-Up tax payment obligations among group members.
If any Hungarian MNE group member is not subject to an advance payment obligation – for instance, due to eligibility for a transitional Safe Harbour – a separate statement must be made in this regard.
With respect to the above-mentioned Transitional Safe Harbour rules, we would like to emphasize that the ministerial decree setting out the detailed rules has not yet been published.
Should you have any questions in relation to the above, please do not hesitate to contact us at tax@bdo.hu.
We would like to draw your attention to the upcoming filing deadline: for MNE group members with a balance sheet date matching the calendar year, the due date for submission of the Prepayment Return is 20 November 2025.
Below, we provide a brief overview of the key elements required for completing the final version of the declaration.
The Prepayment Return should include detailed information regarding both the MNE group members and the amount of the tax advance payment. In particular, it should contain the identification data of the Hungarian group members and the ultimate parent entity, as well as the total amount of the recognized Hungarian Top-Up Tax advance payable by the group. The prepayment must be reported separately by currency – HUF, EUR, or USD – indicating the number of group members applying each currency. In addition, the declaration should specify the amount of advance attributable to each group member in the applicable currency, along with statements regarding the allocation of the Top-Up tax payment obligations among group members.
If any Hungarian MNE group member is not subject to an advance payment obligation – for instance, due to eligibility for a transitional Safe Harbour – a separate statement must be made in this regard.
With respect to the above-mentioned Transitional Safe Harbour rules, we would like to emphasize that the ministerial decree setting out the detailed rules has not yet been published.
Should you have any questions in relation to the above, please do not hesitate to contact us at tax@bdo.hu.