Croatia has aligned its Global Minimum Corporate Tax Act with the OECD GloBE rules and EU Directive 2022/2523, introducing Safe Harbour standards for QDMTT calculations and laying the groundwork for a standardised top-up tax information return under DAC9.
Croatia’s parliament adopted amendments to the Bill on Amendments to the Global Minimum Corporate Tax Act on 5 December 2025, to bring the national rules entirely in line with the OECD GloBE framework and the requirements of EU Directive 2022/2523.
A key change is the introduction of Safe Harbour standards for determining the Qualified Domestic Minimum Top-Up Tax (QDMTT).
Under the revised approach, taxpayers will generally need to calculate their excess profit for QDMTT purposes using the accounting standards applied by the ultimate parent entity when preparing consolidated financial statements.
If this is not feasible, they must use accounting standards that still allow the Safe Harbour to apply. The existing method, using IFRS or Croatian accounting standards, may continue to be used only for the 2024 QDMTT computation.
The amendments also set the basis for a standardised top-up tax information return. The final reporting template will be issued under the amended Act on Administrative Cooperation in Tax Matters, which reflects the changes introduced by the transposition of the Amending Directive to the 2011 Directive on Administrative Cooperation (2025/872) (DAC9).
On 22 December 2023, Croatia published, in the Official Gazette, its approval of the Law on the Minimum Global Profit Tax, following the Croatian Parliament’s adoption of the legislation on 15 December 2023.
