Croatia has published a draft legislation for enforcing the Pillar 2 global minimum tax under Council Directive (EU) 2022/2523 of 14 December 2022.
This includes the introduction of the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) to ensure a minimum tax level of 15% for MNE groups with annual consolidated revenue of at least EUR 750 million. The draft law also includes a provision for a qualified domestic minimum top-up tax (QDMTT).
The IIR and QDMTT will be effective for tax years starting on or after December 31, 2023, while the UTPR will apply to tax years commencing on or after 31 December 2024.
