Page 15 - CEE Tax Guide 2024
P. 15

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
   10   11   12   13   14   15   16   17   18   19   20