Croatia: CbC reporting requirements implemented

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The BEPS Action 13 (Transfer Pricing Documentation and Country-by-Country Reporting) has now been fully implemented in Croatia, with the full legal framework in place. The Croatian Tax Office published the CbC reporting requirements in late March 2017.

The country by country reporting requirement applies to MNEs headquartered in Croatia with annual consolidated group revenue equal to or exceeding €750 million in the previous year. CbCR applies for fiscal years beginning on or after 1 January 2016. A notification stating whether an ultimate parent entity or surrogate parent entity is required to submit a CbC report on behalf of an MNE group. The deadline for submission is 30 April 2017, unless the tax year does not coincide with the calendar year. Each Croatian tax-resident MNE member that is not the ultimate parent, the substitute parent or the constituting member is to notify the Tax Authorities on the name and country of tax residence of the entity that will file the CbCR report on behalf of the MNG it belongs to. The deadline for submission this information is 30 April 2017, unless the tax year does not coincide with the calendar year.

The CbCR is filed by the ultimate parent of those multinational groups (“MNG”) that have total consolidated revenues of EUR 750 million or more in the last financial year.

The first CbC report for the fiscal year started on or after 1 January 2016 must be by an ultimate parent entity of the MNE group or its surrogate parent entity that is resident in Croatia within 12 months from the last day of that tax year. Thus, for the fiscal year that ended on December 31 2016, the deadline is December 31 2017.

Penalties ranging between HRK 2,000 to HRK 200,000 will apply for noncompliance.

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