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The Hungarian Ministry of Finance published on 18 October the draft legislation for public consultation to implement EU Directive 2022/2523/OECD Model Rules on the global minimum tax (GloBE). The draft legislation closely aligns with the OECD Model Rules, Commentary, and Administrative Guidance published thus far.  The draft bill includes the full set of the Pillar Two charging provisions, including: 

  • an Income Inclusion Rule (IIR) and a Qualified Domestic Minimum Top-up Tax (QDMTT) applying in 2024, 
  • an Undertaxed Profits Rule (UTPR) applying in 2025, 
  • a Country-by-Country Report (CbCR) based Safe Harbor legislation, 
  • a Substance Based Income Exclusion amount for all top-up taxes, and 
  • a minimum tax rate at 15%.