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Forvis Mazars in Croatia
Strojarska cesta 20, XVI. Floor,
10 000 – Zagreb, Croatia
(00385) 1 4864 420
 
(00385) 1 4864 429
https://www.forvismazars.com/hr
Pere Mioč
Partner, Tax Services
+385 (0) 1 4864 424
+385 (0) 99 736 8746
pere.mioc@mazars.hr
DETAILED PROFILE

Croatia

Corporate taxes and other direct taxes

Depending on annual revenues, CIT rates in Croatia are set at 18% (on revenues exceeding EUR 995,421.06) or 10% (annual revenues below the prescribed threshold of EUR 995.421,06). Enterprises with annual revenues below EUR 995,421.06 have the option of determining the corporate income tax base using the cash flow principle. Losses can be carried forward for up to 5 years, but special limitations are applicable in case of M&A transactions. Croatia uses thin capitalization (4:1), but thin capitalization does not apply if shareholders are financial institutions or CIT or PIT payers in Croatia. There is a range of tax allowances for new investments, R&D, the education of employees, etc.

A withholding tax of 15% is applied on interest and royalty paid by a Croatian company to a foreign company. Starting from October 12, 2023, there is no longer an obligation to pay withholding tax on market research services, tax and business consulting, and auditing services provided (except for EU non-cooperative jurisdictions). WHT on dividends, profit shares, and performance by foreign performers is set at a rate of 10%. Croatia has 68 active DTT treaties. A withholding tax of 25% is applied on all payments to offshore companies for services not mentioned in the Law. The EU Directives on withholding tax apply. The latest amendments to the Law extend the exemption from taxation of interest and royalty payments between affiliated companies from EU countries to companies from EEA countries (Norway, Iceland, and Liechtenstein)

A 3% real estate transfer tax (RETT) is applied to the transfer of immovable property. The taxable base is the market value of an item of real estate at the moment when the tax liability is incurred and the taxable person is the buyer.

Transfer pricing in Croatia
Arm's length principle Since 2004
Documentation liability Since 2004
APA APA is available as of January 1, 2017.
Country-by-Country liability
Since FY 2017.
Master file-local file (OECD BEPS 13) applicable Master file-local file represents informal legislative framework.
Penalty    
- lack of documentation Not specifically stated, general rules apply (up to EUR 26.545 - for a company and EUR 2.655 - for the responsible individual). 
- tax shortage Additional tax charged and 100% of that tax is non-deductible.
Related parties > 50% (25%)
Direct or indirect control (25% is commonly used by the tax authority and advisors) or joint control functions.
Safe harbors Interest rates on loans between related parties / Simplified approach for low-value adding services (though not mandated by law, it is generally accepted by Tax Authorities in practice).

Level of attention paid by Tax Authority:

8/10

VAT and other indirect taxes

In Croatia, the standard VAT rate is 25%. A reduced rate of 13% applies to services involving the preparation and serving of meals, tourist accommodation services, newspapers, the supply of electrical energy, etc., while a reduced rate of 5% applies to milk, books, etc. The VAT rate of 5% will be applicable to supplies of gas and heating from thermal units, firewood, pellets, briquettes, and wood chips until March 31, 2024. 
The most important VAT-exempt services are banking services, insurance, educational services (under certain conditions), gambling, certain services provided by medical professionals and dentists, and certain other activities. The zero VAT rate (0%) also applies to the supply and installation of solar panels on private residential buildings and public buildings. Activities of public interest are exempt from VAT regardless of their institutional form. Entrepreneurs are obliged to register for VAT purposes during the calendar year in which the total value of supplies exceeds a threshold of EUR 40,000.

Excise duties, special tax on motor vehicles, special tax on coffee and non-alcoholic beverages.

VAT options in Croatia Applicable / limits
Distance selling Threshold for exemption is EUR 10,000/year, similar to other EU member states. OSS applicable.
Call-off stock
VAT group registration
Cash accounting - yearly amount in EUR (approx.)* EUR 2,000.000/year
Import VAT deferment Yes, available to all Croatian VAT payers with the right to full input VAT deduction.
Local reverse charge Construction work, the supply of used materials, the transfer of allowances to emit greenhouse gasses, and, in certain conditions, the supply of immovable property.
Option for taxation
- letting of real estate
- supply of used real estate
VAT registration threshold*

EUR 40,000/year

Personal income tax / Social security system

Instead of the current tax rates of 20% and 30% + possible surtax on income, units of local and regional self-government apply tax rates within the following range, depending on the given local and regional self-government unit: lower rate: 15% - 23.60% (monthly tax base up to EUR 4,200 /annual tax base up to EUR 50,400) and higher rate: 25% - 35.40% (monthly tax base above EUR 4,200 /annual tax base above EUR 50,400). The 12% rate is withheld from certain types of income, e.g. dividends, capital gains, lease of real estate, etc. The payment of occasional awards up to an amount not exceeding EUR 700 (e.g. Christmas and Easter bonus, etc.) and payment of a premium performance award (e.g. bonuses) up to EUR 1,120 per employee per annum is deemed as non-taxable. Also, it should be noted that there are many other non-taxable receipts (employee meal costs, reimbursement of rental costs, etc.). Tax regulations prescribe a non-taxable flat-rate compensation to cover the costs of employees working from home to an amount not exceeding EUR 4 per day working from home, or EUR 70 per month. The examples below show the cost to the employer and the employee in the cases of minimum and average wage levels in the private sector. Basic personal allowance amounts to EUR 560.

Active incomes fall under the scope of the SSC system: individual pension social contributions equal 20% (employee contribution) and health and unemployment contributions of 16.5% represent employer contributions. There are no contributions on salary (16.5%) for a period of 5 years for persons under 30 years of age employed for an indefinite period. Passive incomes are generally only subject to taxes. From January 1, 2024, the base for the calculation of contributions for the 1st pillar pension insurance is reduced. For gross salaries up to EUR 700, the fixed allowance amounts to EUR 300, while for salaries from EUR 700.01 to EUR 1300, the allowance is gradually decreased - 0.5 x (EUR 1,300 – gross salary).

Wage related taxes
in Croatia
Minimum wage
 
Average wage
in private sector
  in EUR in EUR in EUR in EUR
  840 840 1,620 1,620
Total wage cost 979 117% 1,887 117%
Employer's contribution 139 17% 267 17%
Gross salary 840 100% 1,620 100%
Employees' contributions 134 16% 324 20%
Tax and surtax* 35 24% 174 24%
Net salary 672 80.0% 1,122 69.3%

*Tax base differs from the gross salary, deductions apply.