1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?
  2.  What is the implementation status of Pillar Two/GloBE rules?
  3.  Have the local tax authorities published guidelines commenting on Pillar Two/GloBE rules?
  4.  When will the Income Inclusion Rule (IIR) come into force?
  5.  When will the Undertaxed Payments Rule (UTPR) come into force?
  6.  Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

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Croatia
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1.Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

The EU Directive 2022/2523, which provides for minimum taxation of certain multinational enterprise groups and large domestic groups, has been transposed into domestic law. The Minimal Global Corporate Profit Tax Act (in Croatian: Zakon o minimalnom globalnom porezu na dobit) was enacted on 15 December 2023. It came into force on 31 December 2023.

3. Have the local tax authorities published guidelines commenting on Pillar Two/GloBE rules?

No.

4. When will the Income Inclusion Rule (IIR) come into force?

IIR applies to fiscal years commencing on or after 31 December 2023.

5. When will the Undertaxed Payments Rule (UTPR) come into force?

UTPR will apply to fical yars commencing on or after 31 December 2024.

However, if the ultimate parent company is located in EU Member State that elected to postpone the application of the IIR and the UTPR for six years, UTPR will already apply to fiscal years commencing on or after 31 December 2023.

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

DMTT applies to fiscal years commencing on or after 31 December 2023.