The amending protocol, signed during the Three Seas Initiative Summit in Dubrovnik, updates the 2022 income tax treaty to align with current U.S. legislation and Senate requirements on double taxation relief before both documents proceed to ratification.
The US and Croatia have signed an amending protocol to their pending income tax treaty, bringing the agreement closer to ratification. The protocol was signed on 28 April 2026 during the Three Seas Initiative Summit in Dubrovnik by US Ambassador to Croatia Nicole McGraw and Croatian Finance Minister Ćorić.
The original treaty, signed on 7 December 2022, marks the first income tax agreement between the two countries. Both the treaty and the new protocol require ratification before taking effect. Once domestic procedures are complete and ratification instruments are exchanged, both documents will enter into force simultaneously.
The protocol introduces three significant amendments to modernise the 2022 agreement. First, it establishes a treaty-based definition for “active conduct of a trade or business” under Article 22, which addresses limitations on benefits.
Second, it revises Article 23 to update how the United States provides relief from double taxation. Finally, Article 24’s non-discrimination provisions have been modified to align with the One Big Beautiful Bill Act of 2025.
According to the Treasury Department, these changes ensure the treaty conforms with current US law and reflects Senate discussions on double taxation relief standards for new tax agreements. The protocol will be submitted to the US Senate alongside the original treaty for approval.
Earlier, on 9 April 2026, the Croatian government announced the conclusion of negotiations for amending the protocol to the income tax treaty with the US.
