AmCham Recommendations on the Implementation of the Global Minimum Corporate Tax Act

The GMCTA introduces a minimum effective tax rate of 15% for large multinational and domestic groups, reducing the impact of existing tax incentives under the Investment Promotion Act and creating uncertainty for future investments. While the GMCTA, as an EU/OECD standard, cannot be amended, Croatia’s national framework can be adjusted to preserve predictability and competitiveness for investors.

AmCham recommends that:

• Investment Promotion Act to be amended to introduce direct cash grants as a form of incentive instead of corporate tax reductions, thereby maintaining the effectiveness of the incentive system within the Pillar Two rules
   
• Ministry of Finance should adopt a Rulebook on the Minimum Global Corporate Tax to clearly define the interaction between the GMCTA and the Investment Promotion Act, reducing legal uncertainty and potential risks of a top-up tax.

This approach would allow Croatia to remain fully aligned with international standards while continuing to attract major investments that drive productivity, innovation, employment, the green and digital transition of the economy.

AmCham emphasizes that other EU Member States have already introduced grants and clear guidance within the implementation of Pillar Two. It is therefore crucial for Croatia to ensure a predictable, transparent, and competitive incentive framework to remain attractive to investors.

You can read position paper here.