Hungary: CbC reporting and notification requirements | KPMG | BE
close
Share with your friends

Hungary: Country-by-country reporting and notification requirements, deadlines

Hungary: CbC reporting and notification requirements

New issues have emerged regarding Hungary’s country-by-country (CbC) reporting obligation, and specifically several practical questions have arisen in respect of filling the CbC reporting notification on the 17T201T form.

1000

Related content

In an effort to clarify these issues, tax professionals with KPMG in Hungary contacted the tax authority for guidance. Based on these communications, officials with Hungary’s tax authority have outlined the following.

CbC reports and CbC reporting notification requirements

A Hungarian tax resident that is a member of a multinational entity (MNE) group is required to make a CbC reporting-related notification to the tax authority, if the MNE group had an annual consolidated group revenue of €750 million or more in the fiscal year preceding the reporting fiscal year. If the revenue is below the threshold, the Hungarian tax resident is not required to file either the CbC reporting notification or any other declaration with the tax authority.

The CbC reporting requirement for a Hungarian tax resident company can arise in the following situations:

  • As the ultimate parent entity
  • As the surrogate parent entity
  • Due to specific reasons (in line with Section 2 or Section 4 of Paragraph 43/N of Aktv.)

If a MNE group member does not have an obligation to submit a CbC report under one of the above-listed requirements, it must only satisfy the CbC reporting notification requirement.

  • Under general rules, a Hungarian tax resident company is subject to the CbC reporting notification requirement for two reporting fiscal years, together. The first CbC reporting notification is to be filed for the fiscal year beginning on or after 1 January 2016, and for the fiscal year beginning on or after 1 January 2017. 
  • If the 17T201T form cannot be completed and otherwise processed, taxpayers are directed to submit two different notifications (i.e., separate 17T201T forms) to the tax authority—one each for the fiscal year beginning on or after 1 January 2016 and for the fiscal year beginning on or after 1 January 2017. 
  • Information that KPMG tax professionals received from the tax authority indicates that taxpayers need to submit the CbC reporting notification for fiscal year 2016, and then—in practice, a couple of days later—submit the CbC reporting notification for fiscal year 2017.

Deadlines

The statutory deadline for submitting the CbC reporting notification form is as follows:

  • For the fiscal year commencing on or after 1 January 2016—within 12 months from the last day of that fiscal year 
  • For the fiscal year commencing on or after 1 January 2017—by the last day of the fiscal year

Therefore, the statutory CbC reporting notification deadline of both 17T201T forms for a calendar year taxpayer (that is, the taxpayer’s fiscal year is the calendar year) is 31 December 2017 for fiscal year 2016 and for fiscal year 2017. 

For a taxpayer that has a fiscal year ending on 31 March, the statutory notification deadline for filing both 17T201T forms is 31 March 2018 for the fiscal year ending on 31 March 2017 and for the fiscal year ending on 31 March 2018. 

Any change in the information must be reported within 30 days.

 

Read a December 2017 report [PDF 195 KB] prepared by the KPMG member firm in Hungary

 

For more information, contact a KPMG tax professional in Hungary:

Mihály Gódor | +36 1 887 7340 | mihaly.godor@kpmg.hu

Szabolcs Végh | +36 1 887 7213 | szabolcs.vegh@kpmg.hu 

© 2018 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us

 

Request for proposal

 

Submit