Hungary's tax authority has released a technical explanatory guide to assist multinational groups in navigating the country's DAC9 reporting obligations, mapping national requirements against the OECD's GloBE Information Return XML schema and clarifying key data points spanning entity classification, ownership structures, effective tax rate calculations, and top-up tax rules. 

RF Report

Hungary’s National Tax and Customs Administration (NAV) has published an explanatory guide to the GloBE Information Return (GIR) XML schema, aligned with OECD definitions, to clarify data reporting requirements under the country’s DAC9 framework.

Released on 13 May 2026, the guide details the data points set out in the relevant Ministry of Finance decree and is intended to assist taxpayers in meeting their global minimum tax reporting obligations.

The explanatory guide issued provides technical guidance for multinational groups on DAC9/GIR reporting under the global minimum tax framework. It aligns national requirements with the OECD Pillar Two XML schema and clarifies the required data points under the Hungarian decree. It also outlines key reporting elements such as entity identification, ownership structures, and accounting standards for determining GloBE status. In addition, it explains ETR calculations, safe harbours, and top-up tax rules, along with adjustments for deferred taxes, international shipping income, and substance-based income exclusions to support consistent reporting.

The key aspects of the guide’s structure and contents include:

  • OECD alignment: The guide is based on the OECD’s GloBE Information Return (Pillar Two) XML Schema, and it uses specific markings to indicate where various data points are located within that schema’s structure. Furthermore, any reference to “Articles” within the guide refers to the OECD Model Rules.
  • Filing information: It identifies the requirements for the Filing Constituent Entity (Filing CE), including the need for a 2-character ISO country code, the entity’s full legal name, and its Tax Identification Number (TIN) or a functional equivalent like a company registration number.
  • MNE group and accounting details: The reporting includes the name of the Multinational Enterprise (MNE) Group, the start and end dates of the fiscal year, and critical accounting information such as the consolidated financial statement type (CFSofUPE), the applicable accounting standard (FAS), and the currency used.
  • Entity classification and status: The guide explains how to report the GloBE Status for various entities, such as permanent establishments, joint ventures, and minority-owned subsidiaries. It also outlines the reporting for Excluded Entities, such as non-profit organisations or pension funds.
  • Ownership and structural changes: Data points are provided for the ownership structure as of the last day of the fiscal year, as well as any ownership changes that occurred during the year that might affect the Effective Tax Rate (ETR) or Top-up Tax calculations.
  • Summary and jurisdictional reporting: The guide details a “Summary” section that provides a high-level overview of the GloBE Rules’ application by jurisdiction, including the Effective Tax Rate (ETR) range, applicable safe harbours, and the resulting Top-up Tax.