Croatia introduced regulations for its minimum global corporate profit tax, requiring multinational and large domestic groups to designate responsible entities and calculate top-up taxes through new compliance forms. The regulations, published in Narodne novine No. 53/2026 on 15 May 2026, align with OECD Pillar Two standards and establish filing deadlines and joint liability rules for tax obligations.
Croatia’s Ministry of Finance issued the Regulations (Ordinance) of 15 May 2026 on Minimum Global Corporate Profit Tax (published in Narodne novine No. 53/2026), providing the detailed legal framework for implementing the Global Minimum Corporate Tax Act.
These regulations establish the procedures for registering responsible entities, calculating and collecting top-up taxes, and ensuring that Croatian tax practices align with international standards. Furthermore, these rules define the procedural requirements for multinational and large domestic groups to report and settle their tax obligations, specifically through the MGP-DP1 and MGP-DP2 forms.
The “Croatian Subgroup” and the responsible entity
For these regulations, all Croatian constituent entities of an in-scope multinational enterprise (MNE) group or a large-scale domestic group are collectively referred to as the Croatian subgroup.
A central requirement is the identification of a responsible constituent entity for this subgroup. This entity is tasked with:
- Identifying all members of the subgroup subject to the Act in Croatia.
- Formally notifying the Tax Administration of its role in assuming all rights and obligations arising from the tax-legal relationship for the subgroup.
- Submitting the required tax returns and ensuring the accuracy and availability of data.
If the constituent entities of a Croatian subgroup fail to appoint a responsible entity, the Tax Administration has the authority to call upon any constituent entity within the subgroup to fulfil these obligations.
Calculation and collection of top-up taxes
The regulations provide specific guidelines for calculating the Qualified Domestic Minimum Top-up Tax (QDMTT). This calculation is based on the excess profit of the Croatian subgroup, determined according to recognised accounting standards. The responsible entity must ensure that the figures reported are consistent with those in the Global Information Return, though exceptions are made for currency differences if the global return was not filed in euros.
Furthermore, all constituent entities within the Croatian subgroup are jointly and severally liable for the payment of top-up taxes, including the QDMTT and taxes arising from the Income Inclusion Rule (IIR) or the Undertaxed Profits Rule (UTPR).
The total tax liability is treated as a single debt. In instances of non-payment, the Tax Administration will first pursue the responsible entity, but it may initiate enforcement against any other subgroup member if the debt remains unpaid after three months. When selecting which entity to pursue, the authorities may prioritise those with higher revenues in the preceding year.
Filing procedures and deadlines
The regulations introduce two key forms for compliance:
- Form MGP–DP1: Used for the Qualified Domestic Minimum Top-up Tax.
- Form MGP–DP2: Used for reporting top-up tax under the IIR or UTPR.
Generally, the tax return (Form MGP–DP1) must be filed within 15 months of the end of the fiscal year, with the tax payment due 30 days after that deadline. However, for the transitional year, the filing deadline for Form MGP–DP1 and the notification of the responsible entity is extended to 18 months after the end of the fiscal year. Form MGP–DP2 is typically due 30 days after the filing of Form MGP–DP1.
Uniform application of OECD model rules
A core objective of these regulations is to ensure the uniform application of the OECD/G20 Global Anti-Base Erosion (GloBE) Model Rules. The regulations mandate that calculations and data must align with the OECD Model Rules and qualified international safe harbour agreements.
For interpretation and implementation, the responsible entity and the Tax Administration are to rely on official OECD resources, including:
- OECD Administrative Guidance.
- The Commentary to the OECD Model Rules.
- Explanations regarding safe harbour agreements.
- Examples for calculating top-up tax liabilities and other relevant rules published on the OECD’s official website.
This ensures that the Croatian subgroup’s tax obligations are determined in a manner consistent with the international “Pillar Two” framework.
