Three key changes for Hungarian subsidiaries
in June 2025, Parliament accepted the spring tax package, which will make significant changes to global Minimum Tax (Pillar II) domestic application.
The changes in the Act. LIV. 2025. By law are found and were published in the Hungarian Gazette, issue 73.
Although the text of the legislation has not been substantially unchanged compared to the draft submitted, three clarifications have been included, which are explicitly affected by international groups of international companies in Hungary his Hungarian subsidiaries .
1. Extended notice deadline
A new deadline for a global minimum tax report:
last day of the second month following the last day of the tax year - For calendar annual taxpayers this february 28.
Previously, the deadline was the end of December, so the companies concerned will now have two months more time to collect and control the data - either from the parent company or other Hungarian group members.
Tip: Take advantage of the longer deadline for thorough internal negotiations to minimize errors and default risk.
2. A tightening fine
THE default maximum remains HUF 10 million , but from 2025 it can be imposed in the following cases:
- incomplete declaration,
- defective data provision,
- entering false data.
This is the rule august 19, 2025 enters into force.
Important relief:
In the tax years beginning before December 31, 2026, the transitional exemption remains in effect if the company has "acted with care" expected in a given situation.
3. New Accounting Rule - Mandatory Time Directions
as of 1 January 2025, a accounting law requires the expected amount of global minimum tax as a passive time -time I need to book the business year.
After the declaration, this accuracy must be abolished against the actual tax.
Accounting consequences:
- Already at the end of the year, without knowing the final globe, the expected "top-up" tax should be separated.
- The importance of group -level consolidation negotiations and auditing documentation is increasing.
Why is this important?
The purpose of the changes is to make Hungarian regulation better To OECD's standards , but with that, administrative burdens and compliance risks increase.
As a Hungarian subsidiary, it is worthwhile:
- in time to start negotiations with the parent company,
- upgrade to accounting and tax return processes,
- constantly monitor the legislation and accounting rules changes.
If we had our customer, we could help us to comply with the legislation.