Since 2024, Croatia has applied the Minimum Global Corporate Income Tax Act (ZMGPD) (Pillar Two) with a 15% minimum effective rate for large groups, which reduces the effect of tax reliefs under the Investment Promotion Act and creates uncertainty for new investments. Although the ZMGPD, as an EU/OECD rule, cannot be changed, it is possible to adjust the Investment Promotion Act. AmCham advocates timely amendments to maintain predictability and competitiveness, in line with the practices of other EU Member States.

Croatia can remain attractive for large investments and be fully compliant with Pillar Two rules if it gradually redirects tax reliefs into direct grants and adopts a clear Rulebook on the ZMGPD, which increases legal certainty and reduces the risk of top-up tax.

Investments raise productivity and wages, bring technology and R&D, strengthen exports and supply chains, and stabilize tax revenues—in short, they accelerate the green and digital transitions and help retain talent in Croatia.

Since other EU Member States already offer grants and clear rules, especially within the Pillar Two framework, Croatia should ensure an equally predictable, swift, and measurable system of support in order to remain competitive and attract investment.