Croatian Transfer Pricing Regulations

Although Croatia is not an OECD member country, the provisions of the relevant Croatian tax legislation are generally based on the OECD Transfer Pricing Guidelines.

Transfer pricing rules are prescribed by Article 13 of the Corporate Income Tax (CIT) Act and by Article 40 of the CIT Bylaw.

Who is affected?

Pursuant to the relevant provisions (art 13 of the CIT Act and art 40 of CIT bylaw), in the case of mutual business between related parties, if the agreed prices or conditions differ from the prices or conditions which would have been agreed between non-associated parties, the whole amount of the profit that would be realized if the business relations were performed between non-associated parties shall be included in the associated parties' tax bases.