Hungary has initiated a consultation on draft rules for global minimum tax reporting, filing, and payments for large corporate groups.
Hungary’s Ministry for National Economy initiated a public consultation on a draft ministerial decree on 13 December 2025 to establish the detailed implementation rules for reporting, filing, and payment obligations under the global minimum tax (Pillar 2) for large multinational and domestic corporate groups.
The draft decree details mandatory registration and reporting requirements, including the identification of parent companies and designated local entities responsible for tax compliance.
The decree applies to all taxpayers subject to the global minimum tax obligations under Act LXXXIV of 2023 (the Minimum Tax Act). The goal is to provide the procedural framework for how multinational and large-scale domestic groups must notify the authorities, file their returns, and settle their tax liabilities. The rules outline the technical steps for submitting tax returns and calculating top-up tax advance payments to ensure the minimum effective tax rate is met.
One of the most technical aspects of the decree is managing payments in multiple currencies. The regulation provides guidance on currency conversion and payment methods, allowing businesses to fulfil their obligations in HUF, EUR, or USD.
For accounting and tax purposes, the Hungarian National Bank (MNB) exchange rate from the first day of the month in which the return is filed or the payment is received should be used. Any exchange rate differences arising from the conversion to HUF—the official currency for tax records—are the responsibility of the taxpayer. Payments in foreign currency must be transferred to a designated foreign currency account managed by the Treasury.
These rules primarily apply to tax years beginning in 2025, though companies may elect to follow them for the 2024 period.
The decree must be signed by the Minister and published in the Official Journal.
The consultation concluded on 21 December 2025.
