Hungary's Top-Up Tax: Does the 15% Global Minimum Tax Cancel the 9% Rate for Your Company?
Short answer: no, not for a normal owner-managed company. Hungary’s top-up tax only applies to members of a group whose consolidated revenue reached €750 million in at least two of the four preceding years. If your Hungarian Kft. belongs to a founder, a family or a small holding, it has no Pillar Two filings and pays the ordinary 9% corporate income tax. The 15% floor matters only if your company sits inside a large multinational or domestic group. For those groups, Hungary collects the difference itself.
Who is in scope, and who is not
| Your situation | Top-up tax in Hungary? |
|---|---|
| Kft. owned by you or a small holding; group revenue far below €750m | No. 9% CIT, local business tax and the usual returns only |
| Hungarian subsidiary of a group with €750m+ consolidated revenue in 2 of the last 4 years | Yes. Registration, GloBE information return, top-up tax return, advance payment |
| Large group, but the Hungarian entities have tiny revenue and profit (average under €10m revenue and €1m GloBE income) | In scope, but a de minimis election can reduce Hungary’s top-up to zero for that year |
| Government entity, pension fund, non-profit, or investment fund as ultimate parent | Excluded entity under the Act |
The threshold is tested at group level, and the Hungarian Act covers large domestic groups as well as multinationals. A fast-growing company that is acquired by a large group enters the regime through the acquisition, not through its own numbers.
How Hungary’s top-up tax works
Hungary implemented the EU minimum tax directive in Act LXXXIV of 2023. The Act contains three layers:
- Qualified domestic minimum top-up tax (QDMTT). Hungary charges the top-up on low-taxed Hungarian profits itself, so the tax is not collected by the parent’s country instead. It applies to tax years starting after 31 December 2023.
- Income inclusion rule (IIR). A Hungarian parent pays top-up tax on low-taxed foreign subsidiaries. It also applies from years starting after 31 December 2023.
- Undertaxed profits rule (UTPR). This is the backstop, applying to tax years starting after 31 December 2024.
The OECD’s central record lists Hungary’s IIR and QDMTT as qualified from 31 December 2023. It also lists Hungary’s QDMTT as eligible for the QDMTT safe harbour: in principle, other countries switch off their own top-up on Hungarian profits because Hungary already collects it.
Why the effective rate is not simply 15 − 9
The Act lists the taxes that count towards the 15% test. Corporate income tax, local business tax (HIPA), the energy suppliers’ income tax and the innovation contribution are all expressly covered taxes. HIPA can be up to 2% of adjusted revenue (see how it is calculated), so a Hungarian entity’s effective rate for Pillar Two purposes is often well above 9%.
Part of the profit is also carved out. The substance-based income exclusion removes a return on payroll and tangible assets before the top-up is calculated. For tax years starting in 2026 the transitional rates in Annex 9 of the Act are 9.4% of payroll costs and 7.4% of tangible assets, falling gradually to 5%.
Worked example in forints (simplified)
Take a Hungarian manufacturing subsidiary of a €1.2 billion group, for the 2026 tax year:
| Item | Amount |
|---|---|
| GloBE income of the Hungarian entities | HUF 2,000 million |
| Covered taxes: CIT HUF 180 million + HIPA HUF 60 million | HUF 240 million |
| Effective tax rate (240 ÷ 2,000) | 12.0% |
| Top-up percentage (15% − 12%) | 3.0% |
| Substance carve-out: payroll HUF 500m × 9.4% + tangible assets HUF 1,000m × 7.4% | HUF 121 million |
| Excess profit (2,000 − 121) | HUF 1,879 million |
| Hungarian top-up tax (1,879 × 3%) | ≈ HUF 56.4 million |
The real computation has many more adjustments, so treat this as orientation. The point is the order of magnitude: the group pays about 2.8% more on its Hungarian profit, not “15% instead of 9%”.
The same founder-owned Kft. with HUF 80 million profit and a group turnover of a few million euros does none of this. It files its annual corporate tax return and pays 9%. You can compare that route with the dividend options in our guide to taking profit out of a Hungarian company.
Deadlines for groups in scope
| Obligation | Deadline under the Act | Calendar-year example |
|---|---|---|
| Registration with NAV (GLOBE form) | last day of the 2nd month after year-end | 2025 year: 28 February 2026 |
| QDMTT advance payment, equal to the expected top-up | 20th day of the 11th month after year-end | 2025 year: 20 November 2026 |
| GloBE information return and top-up tax return, payment | 15 months after year-end; 18 months for the first year | 2024 year: 30 June 2026 · 2025 year: 31 March 2027 |
The advance is the date to watch this autumn. Returns may be filed in Hungarian or English, and amounts may be stated in HUF, EUR or USD. Where the GloBE information return is filed centrally by the parent in another country, the Hungarian entity instead notifies NAV within six months of that filing.
Penalties under the Tax Administration Act can reach HUF 5 million for a missed registration and HUF 10 million for a missed or incorrect return or GloBE information return. For tax years starting before 31 December 2026 no penalty is imposed if the entity acted as could reasonably be expected.
Safe harbours and what changed in 2026
- Transitional CbCR safe harbour. Groups can use country-by-country report data to show that Hungary’s top-up is zero, for tax years starting on or before 31 December 2026 and not ending after 30 June 2028. The OECD agreed in January 2026 to extend this by one year. As of this update Hungary’s Act still shows the original dates.
- Side-by-side package (OECD, January 2026). Groups whose ultimate parent is in a qualifying jurisdiction can be exempted from the IIR and UTPR, a response to the G7 position on US-parented groups. The package itself says all groups remain subject to QDMTTs. A Hungarian subsidiary of a US group can therefore still owe Hungarian top-up tax, and Hungary has not written a side-by-side safe harbour into its law so far.
What this means if you are opening a company in Hungary
- Check the group, not the company. An investor or acquirer that brings consolidated revenue near €750 million brings Pillar Two with it.
- Below the threshold, the 9% stands. Plan CIT, HIPA, dividend tax and payroll as usual — see our 9% corporate tax overview.
- Holding structures still work. A Hungarian holding meets Pillar Two only through group size, and the participation exemption is unaffected below the threshold.
FAQ
What is the top-up tax in Hungary? A supplementary tax under Act LXXXIV of 2023 that raises the effective tax rate of in-scope groups’ Hungarian profits to 15%. Hungary collects it mainly as a qualified domestic minimum top-up tax.
Does the 15% global minimum tax apply to small companies in Hungary? No. It applies only to members of groups with consolidated revenue of at least €750 million in two of the four preceding years.
Does local business tax count towards the 15%? Yes. The Hungarian Act expressly treats HIPA and the innovation contribution as covered taxes, alongside corporate income tax.
When is the next Hungarian top-up tax payment due? For calendar-year groups, the QDMTT advance for the 2025 tax year is due on 20 November 2026.
Updated: 2026-09-17 · Tax year 2026. This article summarises Hungarian law for orientation. Pillar Two computations depend on group-wide data and elections, and are not tax advice for a specific group.
Setting up in Hungary and want to know which taxes will actually apply to your structure? See how we handle company formation in Hungary, or contact us with your group structure.