Page 14 - CEE Tax Guide 2024
P. 14

Croatia                                                                                                                In Croatia, the standard VAT rate is 25%. A reduced rate   above EUR 4,200 /annual tax base above EUR 50,400).
                                                                                                                                  of 13% applies to services involving the preparation
                                                                                                                                                                                      The 12% rate is withheld from certain types of income,
                                                                                                                                  and serving of meals, tourist accommodation services,   e.g. dividends, capital gains, lease of real estate, etc.
                                                                                                                                  newspapers, the supply of electrical energy, etc., while   The payment of occasional awards up to an amount not
                                                                                                                                  a reduced rate of 5% applies to milk, books, etc. The VAT   exceeding EUR 700 (e.g. Christmas and Easter bonus,
                                                                                                                                  rate of 5% will be applicable to supplies of gas and heating   etc.) and payment of a premium performance award
                               Mazars Cinotti Tax Consulting d.o.o.                                                               from thermal units, firewood, pellets, briquettes, and wood   (e.g. bonuses) up to EUR 1,120 per employee per annum
                               Strojarska cesta 20, XVI. Floor,                                                                   chips until March 31, 2024.                         is deemed as non-taxable. Also, it should be noted that
                               10 000 – Zagreb,                                                                                   The most important VAT-exempt services are banking   there are many other non-taxable receipts (employee meal
                               Croatia                                                                                            services, insurance, educational services (under certain   costs, reimbursement of rental costs, etc.). Tax regulations
                               Phone: (00385) 1 4864 420                                                                          conditions), gambling, certain services provided    prescribe a non-taxable flat-rate compensation to cover
                               Fax: (00385) 1 4864 429                                                                            by medical professionals and dentists, and certain other   the costs of employees working from home to an amount
                               www.mazars.hr
                                                                                                                                  activities. The zero VAT rate (0%) also applies to the supply   not exceeding EUR 4 per day working from home, or EUR
                                                                                                                                  and installation of solar panels on private residential   70 per month. The examples below show the cost to the
                                                                                                                                  buildings and public buildings. Activities of public interest   employer and the employee in the cases of minimum and
                                                                                                                                  are exempt from VAT regardless of their institutional form.   average wage levels in the private sector. Basic personal
           Corporate taxes and other direct taxes              from October 12, 2023, there is no longer an obligation            Entrepreneurs are obliged to register for VAT purposes   allowance amounts to EUR 560.
                                                               to pay withholding tax on market research services, tax            during the calendar year in which the total value of supplies
           Depending on annual revenues, CIT rates in Croatia are set   and business consulting, and auditing services provided   exceeds a threshold of EUR 40,000.                  Active incomes fall under the scope of the SSC system:
           at 18% (on revenues exceeding EUR 995,421.06) or 10%   (except for EU non-cooperative jurisdictions). WHT              Excise duties, special tax on motor vehicles, special tax   individual pension social contributions equal 20%
           (annual revenues below the prescribed threshold of EUR   on dividends, profit shares, and performance by foreign       on coffee and non-alcoholic beverages.              (employee contribution) and health and unemployment
           995,421.06). Enterprises with annual revenues below EUR   performers is set at a rate of 10%. Croatia has 68 active                                                        contributions of 16.5% represent employer contributions.
           995,421.06 have the option of determining the corporate   DTT treaties. A withholding tax of 25% is applied            Personal income tax / Social security system        There are no contributions on salary (16.5%) for a period
           income tax base using the cash flow principle. Losses can   on all payments to offshore companies for services not                                                         of 5 years for persons under 30 years of age employed
           be carried forward for up to 5 years, but special limitations   mentioned in the Law. The EU Directives on withholding   Instead of the current tax rates of 20% and 30% +   for an indefinite period. Passive incomes are generally
           are applicable in case of M&A transactions. Croatia uses   tax apply. The latest amendments to the Law extend          possible surtax on income, units of local and regional   only subject to taxes. From January 1, 2024, the base for
           thin capitalization (4:1), but thin capitalization does not   the exemption from taxation of interest and royalty      self-government apply tax rates within the following   the calculation of contributions for the 1st pillar pension
           apply if shareholders are financial institutions or CIT or PIT   payments between affiliated companies from EU countries   range, depending on the given local and regional self-  insurance is reduced. For gross salaries up to EUR 700, the
           payers in Croatia. There is a range of tax allowances for new   to companies from EEA countries (Norway, Iceland, and   government unit: lower rate: 15%–23.60% (monthly   fixed allowance amounts to EUR 300, while for salaries
           investments, R&D, the education of employees, etc.                                                                     tax base up to EUR 4,200 /annual tax base up to EUR   from EUR 700.01 to EUR 1300, the allowance is gradually
                                                               Liechtenstein).
           A withholding tax of 15% is applied on interest and royalty   A 3% real estate transfer tax (RETT) is applied to the   50,400) and higher rate: 25%–35.40% (monthly tax base   decreased – 0.5 x (EUR 1,300 – gross salary).
           paid by a Croatian company to a foreign company. Starting
                                                               transfer of immovable property. The taxable base is the
                                                               market value of an item of real estate at the moment
            Transfer pricing in Croatia                        when the tax liability is incurred and the taxable person

            Arm's length principle   ü         since 2004      is the buyer.
                                                                                                                                                                                                                   Average wage
            Documentation liability  ü         since 2004      VAT and other indirect taxes                                        Wage related taxes in Croatia                       Minimum wage               in private sector
                                              APA is available
            APA                   ü         as of January 1, 2017.  VAT options in                                                                                                     in EUR       in EUR        in EUR       in EUR
            Country-by-Country                                  Croatia                Applicable / limits                                                                               840           840          1,620       1,620
            liability             ü           Since FY 2017.                                                                       Total wage cost                                        979        117%           1,887       117%
            Master file-local file                              Distance selling    Threshold for exemption is EUR 10,000/
                                                                                    year, similar to other EU member states.
            (OECD BEPS 13)        No     Master file-local file represents                 OSS applicable.                                                     Employer's contribution    139         17%            267         17%
                                         informal legislative framework.
            applicable                                                                                                             Gross salary                                           840        100%           1,620      100%
            Penalty                                             Call-off stock                 ü                                                              Employee's contributions    134         16%            324        20%
                                         Not specifically stated, general   VAT group registration  No                                                               Tax and surtax*       35         24%             174        24%
                                         rules apply (up to EUR 26,545
              lack of documentation   ü  – for a company and EUR 2,655   Cash accounting – yearly                                  Net salary                                             672       80.0%           1,122      69.3%
                                         for the responsible individual).   amount in EUR (approx.)  EUR 2,000,000/year
                                                                                                                                  * Tax base differs from the gross salary, deductions apply.
                                           Additional tax charged
                     tax shortage  ü        and 100% of that tax    Import VAT deferment  Yes, available to all Croatian VAT payers
                                             is non-deductible.                     with the right to full input VAT deduction.
                                           Direct or indirect control                Construction work, the supply of used
            Related parties      > 50%   (25% is commonly used by the                materials, the transfer of allowances
                                  (25%)   tax authority and advisors)   Local reverse charge  to emit greenhouse gasses, and,
                                           or joint control functions.                in certain conditions, the supply
                                         Interest rates on loans between                 of immovable property.
                                          related parties / Simplified   Option for taxation
                                         approach for low-value adding
            Safe harbors          ü      services (though not mandated   letting of real estate  No                                              Pere Mioč
                                         by law, it is generally accepted                                                                        Partner – Tax Services
                                         by Tax Authorities in practice).  supply of used real estate  ü                                         Mobile: +385 (0)99 736 8746
            Level of attention paid by Tax                      VAT registration          EUR 40,000/year                                        E-mail: pere.mioc@mazars.hr
            Authority                            8/10           threshold

           14    Mazars                                                      Central and Eastern European tax guide 2024          Central and Eastern European tax guide 2024                                             Mazars   15
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