Croatia country profile

Croatia country profile

Key tax factors for efficient cross-border business and investment involving Croatia.

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EU Member State

Yes.

Double Tax Treaties

Albania Hungary Netherlands
Armenia Iceland Norway
Austria India Oman
Azerbaijan Indonesia Poland 
Belarus Iran  Portugal
Belgium Rep. of Ireland Romania
Bosnia & Herzegovina Israel Russia
Bulgaria  Italy San Marino
Canada Jordan Serbia
Chile Rep. of Korea Slovakia
China Kuwait  Slovenia
Czech Rep Latvia  South Africa
Denmark Lithuania Spain
Egypt Macedonia Sweden
Estonia Malaysia Switzerland
Finland Malta Syria
France Mauritius  Turkey
Georgia
Morocco Turkmenistan
Germany  Moldova UK 
Greece  Montenegro Ukraine

Forms of doing business

Joint-stock company ("dioničko društvo - d.d.") and limited liability company ("društvo s ograničenom odgovornosti - d.o.o.").

Legal entity capital requirements

Registered share capital of HRK 200,000 for joint-stock companies. Registered share capital of HRK 20,000 for limited liability companies.

Residence and tax system

A company is resident if its registered office or its place of management and supervision of business is located in Croatia.

Resident companies are taxed on their worldwide income. Non-resident companies are taxed only on their Croatian source income.

Compliance requirements for CIT purposes

Taxpayers are required to submit a CIT return no later than four months following the end of the tax period. Medium-sized and large taxpayers as well as all VAT taxpayers are required to submit the CIT return electronically.

Balance Sheet and Income Statement should be submitted together with the CIT return.

Tax rate

The standard corporate income tax rate is 20 percent. This may be reduced to 10 percent, 5 percent or 0 percent based on certain investment related incentives or if the company is located in a free zone or a special support area, provided certain conditions are met.

Withholding tax rates

On dividends paid to non-resident companies

12 percent on dividends and profit shares.

On interest paid to non-resident companies

The WHT rate on interest is generally 15 percent. However, WHT is not applied on interest in relation to the following:

  • Interest paid on loans provided by banks and other financial institutions;
  • Interest paid on commodity loans for goods purchased in order to conduct
    business activity;
  • Interest paid to holders of corporate bonds.

On patent royalties and certain copyright royalties paid to non-resident companies

15 percent.

On fees for technical services

20% if payments are made to tax havens.

On other payments

15% on payments for market research, tax and business advisory and audit services.

Branch withholding taxes

No.
 

Holding rules

Dividend received from resident/non-resident subsidiaries

Dividends are not taxable in Croatia when received.

Capital gains obtained from resident/non-resident subsidiaries

Capital gains should be included in the annual corporate income tax calculation.
 

Tax losses

Tax losses can be carried forward for up to five years. Tax loss carry-back is not available.

Tax consolidation rules/Group relief rules

No.

Registration duties

No.

Transfer duties

On the transfer of shares

No.

On the transfer of land and buildings

Real estate transfer tax applies on transfer of land and certain buildings at 5 percent.
 

Stamp duties

No.

Real estate taxes

No.

Controlled Foreign Company rules

No.

Transfer pricing rules

General transfer pricing rules

Yes.

Documentation requirement?

Supporting documentation of the arm's length nature of transactions with related parties is required.

Thin capitalization rules

Yes, limited application, 4:1 debt-to-equity ratio for interest expenses.

General Anti-Avoidance rules (GAAR)

General anti-avoidance rules apply.

Specific Anti-Avoidance rules/Anti Treaty Shopping Provisions

No.

Advance Ruling system

Yes.

IP / R&D incentives

Taxpayers can additionally decrease their taxable base by 150 percent of eligible expenses incurred for basic research, 125 percent for practical research, 100 percent for developmental research. In addition, small and medium-sized entrepreneurs, as defined by the Accounting Law, can additionally increase the abovementioned incentives by 20 percent (small) or 10 percent (medium-sized) of the eligible R&D expenses for practical and developmental research.

Other incentives

Incentives for education and training are also available up to a maximum of 70 percent of eligible expenses depending on the type of education and training (general or specific) and the type of business (small, medium or large). These incentives can be further increased by 5 percent or 10 percent if the business activity is carried out in the areas that meet the conditions for the application of regional state support and by a further 10 percent if the worker sent on education and training is a disadvantaged worker (e.g. is younger than 25 years of age and has never had any job with regular pay, is disabled, etc.).

VAT

The standard rate is 25 percent, and the reduced rates are 13 and 5 percent.

Other relevant points of attention

WHT of 15 percent applies on business advisory services (i.e. market research services, tax and business consultancy, and audit services).

A WHT rate of 20 percent on payments for services also applies under domestic tax law, but only for payments for services to entities tax resident in certain countries.

Contact us

Paul Suchar

KPMG in Croatia

T: +385 (0)1 5390 032

E: psuchar@kpmg.com

EU Tax Centre

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