Hungary's tax authorities have issued detailed technical guidance for multinational enterprises on global minimum tax reporting under the OECD's GloBE Information Return framework. The 13 May 2026 guidance clarifies data submission requirements under DAC9, including XML schema definitions, effective tax rate calculations, and substance-based income exclusions mandated by Ministerial Decree 46/2025.
Hungary’s tax authorities released comprehensive guidance on 13 May 2026 addressing the reporting requirements for global minimum tax obligations. This guidance provides taxpayers with clarity on the detailed data submissions required under recently established regulations.
This guidance provides an official technical guide for multinational enterprises to complete the OECD’s GloBE Information Return (GIR), specifically focusing on the DAC9/GIR data reporting requirements. It outlines the precise XML schema definitions and data points necessary to identify filing constituent entities, group structures, and their respective tax jurisdictions.
The text details complex calculations for the effective tax rate (ETR), qualified domestic minimum top-up taxes, and substance-based income exclusions. Furthermore, it clarifies how to report ownership changes, deferred tax adjustments, and specific exemptions for international shipping or international activity.
Taxpayers must now provide specific data points as outlined in Ministerial Decree 46/2025, enacted on 23 December 2025. These requirements stem from the global minimum tax provisions introduced through the Amending Directive to the 2011 Directive on Administrative Cooperation, known as DAC9 (Directive 2025/872). The reporting obligations are further established under Section 44 of Act LXXXIV of 2023, which addresses additional taxes ensuring a global minimum tax level.
The guidance document explains each data point specified in Annex 1 of the Ministerial Decree, drawing from the field definitions established in the OECD GloBE Information Return (GIR) XML schema. This standardised framework enables consistent data generation and electronic transmission across jurisdictions. The OECD has made the GIR XML Schema Guide publicly available on its website, providing taxpayers with detailed definitions of required data fields.
Below is an elaboration on the key components and requirements outlined in the documentation:
General reporting information (Filing info)
The guide begins by identifying the Filing Constituent Entity (Filing CE), which is the entity responsible for submitting the GloBE return.
- Identification: The Filing CE must provide its full legal name, Tax Identification Number (TIN), and its specific role within the group (e.g., Ultimate Parent Entity – GIR401, or Designated Filing Entity – GIR402).
- Reporting Scope: If the group opts for local filing, the relevant jurisdiction code must be provided.
- MNE Group Details: Information such as the group’s name used in consolidated financial statements and the specific fiscal year (start and end dates) is required.
Accounting and identification of entities
The return mandates that the Filing Constituent Entity specify the financial accounting standard (FAS) applied by the Ultimate Parent Entity for consolidation purposes. All monetary figures must be presented in the currency of the UPE’s consolidated financial statements and rounded to whole numbers. Additionally, each Constituent Entity, Joint Venture, and JV subsidiary requires identification through its jurisdictional country code alongside its designated GloBE Status classification, such as standard member, Permanent Establishment, or Investment Entity.
Corporate structure and ownership changes
The documentation highlights the importance of documenting group structure and any changes throughout the reporting period. The ownership framework must be presented as it exists on the final day of the tax year, detailing both direct and indirect holdings by Ultimate Parent Entities, Joint Ventures, or external parties. Any modifications to ownership arrangements or entity classifications that affect the Effective Tax Rate or Top-up Tax distribution must be disclosed, including the date when changes took effect and the entity’s previous status before the modification.
Summary and executive overview
A specific “Summary” section provides a high-level jurisdiction-by-jurisdiction overview of the GloBE Rules’ application.
- Safe harbours: It indicates if Top-up Tax was reduced to zero due to various safe harbours, such as the Qualified Domestic Minimum Top-up Tax (QDMTT) safe harbour or the Transitional CbCR Safe Harbour.
- ETR ranges: For jurisdictions not covered by a safe harbour, the group must report which range the ETR falls into (e.g., 12.5% to 15%).
- Tax ranges: It also tracks the range of the payable QDMTT and the final GloBE Top-up Tax.
Detailed ETR and top-up tax calculations
- Financial Accounting Net Income or Loss requires adjustments for specific GloBE items, including excluded dividends and equity gains, to determine Net GloBE Income
- Covered Taxes identification involves recording tax expenses from financial accounts with necessary adjustments, including allocations from Controlled Foreign Company tax regimes
- Deferred tax assets and liabilities must be reported with detailed instructions requiring recasting at the 15% minimum rate
- Substance-based Income Exclusion allows groups to reduce excess profit subject to tax based on payroll cost percentages and tangible asset carrying values within jurisdictions
Special rules and mechanisms
- Qualified Domestic Minimum Top-up Tax jurisdictions require detailed reporting of payable amounts and the accounting standards applied for calculations
- Undertaxed Profits Rule allocation distributes Top-up Tax between jurisdictions based on employee headcount and tangible asset values
- International shipping activities have specific data points for excluding related income and costs from calculations.
