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Croatia: Amendments to the Croatian Corporate Income Tax Act


David Jakovljevic

The Croatian Parliament approved the EU Parent-Subsidiary Directive (2011/96/EU) and subsequent amendments to it (2015/121/EU). It also passed amendments to the Croatian Corporate Income Tax Act (CIT Act) on May 13 2016, which was published in the Official Gazette no. 50/2016 and entered into force on June 9 2016.

The amendment essentially introduces an article by which all tax exemptions, tax reductions, tax reliefs and other benefits provided for by the CIT Act cannot be granted if the tax authority determines that such benefits are a result of arrangements or business activities which, having all the facts and circumstances into consideration, are not genuine and authentic, thereby effectively resulting in tax evasion.

The phrase "non-genuine arrangements or business activities" in the amended CIT Act refers to any business transactions, activity, schemes, agreements, obligations or events, consisting of one or more parts, which are not made for valid commercial purposes or do not reflect the economic reality. According to the law, such activities are being tracked as of June 1 2016.

David Jakovljevic (

Eurofast Global Croatia


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