Our Services
Global Minimum Tax Services
C&H Partners Tax Consulting Kft. provides expert support in interpreting Global Minimum Tax rules, determining whether businesses fall within their scope, preparing the relevant calculations and reporting, and meeting related tax obligations in Hungary.
Global Minimum Tax advisory for multinational and large corporate groups may cover the entire process, from assessing whether the rules apply to the group and applying the Safe Harbour and QDMTT rules to fulfilling the relevant notification and tax return filing obligations.
How can we help with Global Minimum Tax advisory?
Global Minimum Tax (GloBE) Scope and Taxpayer Status Assessment
We assess whether a company or group falls within the scope of the Global Minimum Tax rules. This includes reviewing the group structure, the annual financial data reported in the ultimate parent entity’s consolidated financial statements, and the entities within the group, including any excluded entities.
We also pay particular attention to the treatment of permanent establishments under the GloBE rules, as the legislation includes permanent establishments within the definition of a constituent entity. Based on our assessment, we determine the entity’s GloBE status in Hungary and the main obligations arising from it.
Safe Harbour Eligibility Assessment
The CbCR Safe Harbour determines whether a group may be exempt from detailed GloBE calculations based on three tests: the simplified effective tax rate test based on CbCR data, the de minimis test, and the routine profits test.
We assess whether the group may qualify for any of the Safe Harbour simplifications available under the GloBE rules in a particular jurisdiction. Based on the available financial, tax, and jurisdictional data, we review the eligibility criteria and perform the necessary calculations.
QDMTT Calculations
We review the data relevant to the Qualified Domestic Minimum Top-up Tax (QDMTT) for group entities located in Hungary and calculate the top-up tax attributable to Hungary under the GloBE rules.
As part of the calculation, we determine the qualifying income attributable to Hungary, assess the applicability of adjustments, identify the relevant covered taxes and calculate the effective tax rate. We then calculate any excess profit and the QDMTT payable, if applicable.
Assessment of IIR and UTPR Obligations
In addition to the Hungarian QDMTT, we assess whether the group structure may give rise to the application in Hungary of the Income Inclusion Rule ("IIR") or the Undertaxed Profits Rule ("UTPR").
When assessing the IIR, we review whether a parent entity or intermediate parent entity located in Hungary may have IIR obligations in respect of low-taxed foreign constituent entities within the group.
When assessing the UTPR, we analyse whether any top-up tax remaining in respect of low-taxed constituent entities of a multinational group may be allocated to Hungary. This may be particularly relevant where, for example, the ultimate parent entity is located outside the European Union in a jurisdiction that does not apply a Qualified IIR, or where the ultimate parent entity itself is low-taxed and the additional statutory conditions are met.
We consider the group’s overall ownership and operating structure to determine which top-up tax collection mechanisms may be relevant in Hungary.
Global Minimum Tax (GloBE) Compliance and Reporting
GloBE taxpayer notification: we prepare and, where applicable, submit the notification of GloBE taxpayer status using the GLOBE form. The notification must be filed by the last day of the second month following the end of the tax year.
QDMTT advance tax: we calculate the expected domestic minimum top-up tax advance payment for the tax year and prepare the return to be filed using the GLBADO form. The advance tax return must be filed and the advance paid by the 20th day of the eleventh month following the end of the tax year.
Annual GloBE/QDMTT tax return: we prepare the annual tax return, including the data and calculations required to determine the final tax liability. As a general rule, this return must be filed by the end of the fifteenth month following the tax year.
GIR reporting: we support the collection and processing of the data required to prepare the GloBE Information Return ("GIR") and assist with meeting the reporting obligation.
Learn more about our GIR reporting services →
GloBE compliance obligations may remain relevant even where a group qualifies for relief from full GloBE calculations or payment of top-up tax under a Safe Harbour rule. Eligibility for a Safe Harbour therefore does not automatically eliminate notification, reporting, or tax return filing obligations.
What Do We Offer Our Clients?
We prepare technical summaries, analyses, and calculations tailored to each GloBE matter, and support clients in meeting related compliance obligations and preparing the required reports.
GLOBAL MINIMUM TAX · GLOBE COMPLIANCE
Global Minimum Tax Compliance with expert support
Our Global Minimum Tax advisory services include assessing QDMTT obligations, determining whether Safe Harbour rules may apply, and assisting with related tax returns and reporting. This enables us to provide clients with coordinated professional support for GloBE compliance.
Meeting GloBE obligations often requires the coordination of data from group entities operating in multiple jurisdictions. Our ongoing engagements include Global Minimum Tax calculations, compliance, and reporting matters. Drawing on our experience, we help clients organise data and prepare and compile group-level reporting.
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Global Minimum Tax Compliance Obligations
GloBE taxpayer notification
Filing advance tax returns
Preparation and filing of tax returns
GIR reporting
Transparent processes. Coordinated data. Expert support.
Global Minimum Tax Compliance and Practical Expert Support
Meeting Global Minimum Tax Compliance Obligations
We provide our clients with comprehensive professional support in meeting their Global Minimum Tax compliance obligations. We assist with processing the required data, preparing calculations and tax returns, and handling advance tax payments and other administrative tasks. Our aim is to ensure that the GloBE compliance process is transparent, coordinated, and aligned with applicable requirements.
Preparing GIR Reports for International Groups
As part of our ongoing projects, we support the preparation of GIR reports for corporate groups. We focus on collecting, organising, and processing the required information and coordinating group-level data. Drawing on our experience, we also assist with reporting tasks covering the group as a whole.
Global Minimum Tax Advisory for Group Reorganisations and Restructuring
Changes to a group’s structure, organisational arrangements, or business activities may have implications under the Global Minimum Tax rules. We advise groups planning a reorganisation or restructuring by assessing proposed changes from a GloBE perspective, identifying potential tax consequences, and highlighting factors relevant to informed decision-making.
Global Minimum Tax (GloBE) Advisory: Step by Step
Applying the Global Minimum Tax rules can involve a series of connected tasks, from determining whether the rules apply to performing calculations and meeting compliance requirements. Our advisers provide support at each stage, tailored to the needs of the group.
Step 1
Scope assessment
We assess whether the group falls within the scope of the GloBE rules.
Step 2
Data and obligations
We identify the required data, calculations, and related obligations.
Step 3
Global Minimum Tax (GloBE) calculations
We assist with the required calculations, including determining the effective tax rate.
Step 4
Tax returns and reporting
We support clients in meeting related tax return filing and reporting obligations.
Step 5
Ongoing support
We remain available to assist with subsequent questions, changes, and practical GloBE matters.
To learn more about our Tax Compliance services related to Global Minimum Tax, click here to review the tax returns and reporting obligations that companies may be required to fulfil.
Frequently Asked Questions
We have compiled answers to some of the most frequently asked questions about Global Minimum Tax and the application of the GloBE rules.
What is the Global Minimum Tax (GloBE)?
The Global Minimum Tax (GloBE) forms part of the OECD’s Pillar Two initiative, which aims to reduce opportunities for tax avoidance by multinational enterprises and promote a fairer distribution of taxation among jurisdictions.
Who may be subject to the Global Minimum Tax rules?
The GloBE rules may apply to multinational enterprise groups and large-scale domestic groups whose annual revenue reaches or exceeds EUR 750 million in at least two of the four preceding fiscal years. Certain entities, such as investment funds and non-profit organisations, may qualify as excluded entities; their revenue may be relevant to the threshold calculation, but they are not subject to top-up tax in their capacity as excluded entities.
What if the ultimate parent entity’s financial year differs from that of the domestic subsidiary?
Under the relevant legislation, the fiscal year is the reporting period for which the group’s ultimate parent entity prepares consolidated financial statements. Accordingly, the ultimate parent entity’s financial year generally needs to be considered when determining the obligations to be fulfilled. However, based on information received from the tax authority, the notification of taxpayer status should be filed in line with the subsidiary’s own financial year.
What types of de minimis relief are available under the GloBE rules?
Under the Safe Harbour de minimis test, it must be assessed whether total revenue for the fiscal year is below EUR 10 million and profit before tax is below EUR 1 million in Hungary. For the permanent de minimis exclusion, the average qualifying revenue and average profit of Hungarian constituent entities must also be assessed over a three-year period.
What tax return and reporting obligations arise under the Global Minimum Tax rules?
Affected taxpayers must notify the tax authority of their top-up tax status for each tax year. The notification must be submitted by the last day of the second month following the end of the relevant tax year. In addition, taxpayers subject to the Qualified Domestic Minimum Top-up Tax must determine and report their advance payment obligation by the 20th day of the eleventh month following the end of the tax year. An annual tax return and a GIR report must also be filed.
Can local business tax and the innovation contribution be taken into account when calculating the ETR?
For the purposes of calculating the domestic top-up tax, local business tax and the innovation contribution may be taken into account as covered taxes. However, when applying CbC Safe Harbour relief, a more detailed interpretation of the legislation indicates that only income taxes may be included in the simplified ETR test.
When should you seek GloBE advice?
Expert advice can be useful even if you initially only want to determine whether your group falls within the scope of the Global Minimum Tax rules. Our advisers can assist with scope assessments, GloBE calculations and reporting, and ongoing professional support.
Could the rules apply to your group?
Are you unsure whether your group falls within the scope of the Global Minimum Tax rules? We can help assess whether the rules apply, perform GloBE calculations, and address related compliance requirements.