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.
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.
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:
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.
The statutory deadline for submitting the CbC reporting notification form is as follows:
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 | firstname.lastname@example.org
Szabolcs Végh | +36 1 887 7213 | email@example.com
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