Croatia

Transfer Pricing in Croatia

Croatian transfer pricing (transferne cijene) in tax year 2026. It covers who counts as a related person (Profit Tax Act art. 13(2) and General Tax Act art. 49), when purely domestic deals are caught (art. 13(5): tax-privileged party or losses carried forward), the arm's length rule and the five methods (art. 13(1) and (3)), documentation and the compensating adjustment (Profit Tax Rulebook art. 40), the PD-IPO related-party form filed with the PD return and its 2026 e-invoice carve-out, the Minister of Finance interest rate for related-party loans (2.65% for 2026), thin capitalisation (art. 8), APAs (art. 14.a and the APA rulebook fees), country-by-country reporting and fines.