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Hungarian businesses facing key decisions affected by Pillar Two implementation focus on accessing transitional safe harbor

09 May 2024

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Tax Alerts, Information Reporting, Legis...

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Hungary

With Hungary's Base Erosion and Profit Shifting (BEPS) 2.0 Pillar Two legislation now effective, and the Income Inclusion Rule (IIR) and a Qualified Domestic Minimum Top-up Tax (QDMTT) applicable from 1 January 2024, qualifying for one of the available safe harbors will be important for many businesses.Executive summaryHungary's Pillar Two legislation introduced a QDMTT at a minimum rate of 15% while Hungary retained its 9% statutory domestic corporate income tax rate. Hungary adopted transitional country-by-country reporting (CbCR) safe harbor rules and meeting one of the safe harbor tests in 2024 is the first step a multinational entity (MNE) must take...