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

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 summary

Hungary'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 transition…