Corporate - Significant developments

Last reviewed - 30 June 2021

Croatia adjusted its legislation to mandatory European Union (EU) Directives (ATAD I and ATAD II) within the Corporate Income Tax (CIT) Act provisions in relation to exit taxation and hybrid instrument rules. Exit taxation and hybrid mismatch rules are applicable along with the submission of the CIT return for 2020, while the provisions in relation to the reverse hybrid mismatch will apply at the time of submission of the CIT return for 2022. 

As of 1 January 2020, Croatia also implemented the Council Directive 2018/822 of 25 May 2018 amending Directive 2011/16/EU in relation to reportable cross-border arrangements (DAC6) through the Act on administrative cooperation in the field of taxation and Rulebook on the automatic exchange of information in the field of taxation.

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (hereinafter: “MLI”) negotiated within OECD/G20 which modifies bilateral tax treaties in order to eliminate double taxation entered into force in Croatia on 1 June 2021. Croatian MLI covers 65 DTT's.