With a total of 15 action points, the OECD's Base Erosion
and Profit Shifting (BEPS) project aims at fighting the artificial
shift of profits from jurisdictions with high taxes to tax havens,
often as a part of an entirely legal strategy used by MNEs.
The BEPS Action 13 (Transfer Pricing Documentation and
Country-by-Country Reporting) imposes to multinationals the
so-called Country-by-Country (CbC) Report by which MNEs must
annually report certain information about their business. The CbC
is filed in every tax jurisdiction in which a given MNE
operates.
Action 13 has now been fully implemented in Croatia, with the
full legal framework in place. The Act on Administrative
Cooperation in the Field of Taxation, in force as of January 1,
2017, as a separate section of the old General Tax Act, adopts and
implements various EU Directives in the area of administrative
support and automatic exchange of information between EU member
states. Based on this Act, the Ordinance
