GLOBAL MINIMUM TAX

The Ordinance on the Minimum Global Tax has now been officially published. At the same time, the Tax Administration issued an official notice on the postponement of the deadline for submitting the GloBE Information Return (“GIR“), as well as the notification regarding the entity submitting the GIR. Below is an overview of the most important clarifications from the published Ordinance and the new filing deadlines.

Croatian Subgroup and Designated Filing Entity

The Ordinance introduces the concept of a Croatian Subgroup, comprising all entities of the same multinational enterprise (MNE) group operating in Croatia. The Croatian Subgroup must be assigned a designated name under which it will be registered with the Tax Administration.

Furthermore, the Ordinance clarifies on the requirement to organize tax responsibilities among entities within the Croatian Subgroup. Where multiple entities of the same MNE group operate in Croatia, one domestic entity must be appointed as the Designated Filing Entity. This entity is responsible for filing tax returns, calculating, and paying the top-up tax on behalf of the entire Croatian Subgroup. All entities within the Croatian Subgroup are jointly and severally liable for the payment of the top-up tax.

Calculation of the Qualified Domestic Top-up Tax (QDMTT)

The Ordinance further clarifies that the calculation of the Qualified Domestic Top-up Tax (QDMTT) is based on the accounting standard applied in preparing the Ultimate Parent Entity’s consolidated financial statements, or on an accounting standard that ensures the application of a qualifying international safe harbor agreement. The principles of the Income Inclusion Rule (IIR) are applied for the purposes of the tax calculation.

Tax Reporting Forms

The Ordinance clarifies that the filing of the GloBE Information Return is deemed fulfilled if it is submitted in accordance with the provisions of the Act on Administrative Cooperation in the Field of Taxation and the Ordinance on Automatic Exchange of Information in the Field of Taxation, which set out in detail the content and method of filing.

The following forms have been published for use in the reporting process:

– Top-up Tax Return under the Income Inclusion Rule (IIR) / Undertaxed Profits Rule (UTPR); and

– Qualified Domestic Top-up Tax (QDMTT) Return.

These filings also serve to notify the Tax Administration of the Designated Filing Entity, as well as to submit the list of companies forming the Croatian Subgroup.

The filing of the Qualified Domestic Minimum Top-up Tax return is mandatory, even if no top-up tax liability arises in Croatia.

New deadlines for filings for the fiscal year ending 31 December 2024

The Tax Administration has postponed the deadline for submitting the Notification of the Entity Filing the GIR from 31 May 2026 to mid-June 2026, i.e. until submission through the e-Porezna system becomes available.

Submission of the GIR for companies filing in Croatia will be enabled in the fourth quarter of 2026, while the final deadline and additional instructions will be announced by the Tax Administration at a later date.

The deadline for submitting the Qualified Domestic Top-up Tax Return and the Top-up Tax Return currently remains unchanged and expires on 30 June 2026.

If you have any questions or concerns regarding your obligations under the global minimum tax, you can always contact our tax team with confidence.