Croatia Issues a Draft Ordinance to Provide for Pillar Two Administrative Amendments

Article 2 requires the responsible constituent entity to identify all Croatian constituent entities within scope, create the domestic concept of the Croatian subgroup (Podskupina RH), determine the name under which that subgroup will be registered, notify the Tax Administration that it has assumed the relevant tax-law rights and obligations, submit the list of Croatian subgroup entities, and do so by the deadline for filing the domestic QDMTT return. If the group does not comply, the Tax Administration may call on any Croatian constituent entity.

This therefore creates a Croatian filing cluster that makes consolidated local returns workable under the 2025 amendments that added consolidated filing by the responsible entity (2025 amending law, Articles 6 and 7). 

Notification must be made by the last day for filing the QDMTT return, rather than by the later IIR/UTPR return deadline. 

Article 2(6) and (7) uses the domestic return forms themselves as the method of  notification. There is no standalone Croatian responsible entity notice.

Article 3 – Liability for payment

Article 3 states that the total top-up tax liability of the Croatian subgroup is a single debt, records that debt on the responsible entity’s tax account, requires electronic notice to all jointly liable debtors, and sets an enforcement sequence under which collection is pursued first against the responsible entity and, if unsuccessful after three months, against another jointly liable Croatian constituent entity.

Article 4 – Data for determining top-up tax liability