Croatia has enacted Law No. 2167 implementing the Crypto-Asset Reporting Framework (CARF) and enhanced automatic exchange of information (AEOI) provisions, published in the Official Gazette on December 3 and taking effect December 11, 2025.
CARF Implementation
The legislation establishes comprehensive reporting obligations for crypto-asset service providers, requiring them to collect, report, and retain information on users and transactions. Providers must register with the Tax Administration by June 30, 2027, for reporting obligations beginning January 1, 2026.
Crypto-asset service providers authorized by the Croatian National Bank under MiCA regulations, or those meeting specific residency and business presence criteria in Croatia, must report detailed transaction information including user identification data, transaction amounts, and crypto-asset types. The framework includes due diligence procedures similar to those under the Common Reporting Standard.
Providers failing to obtain required information after two reminders following an initial request must prevent users from conducting reportable transactions after 60 days. The Tax Administration will assign individual identification numbers to registered entities and notify all EU member state authorities.
Enhanced AEOI Rules
The amendments expand automatic exchange of information to include non-custodial dividends and strengthen reporting requirements for financial account information. Financial institutions must obtain valid residency statements from account holders and reporting persons, with enhanced identification requirements for undocumented accounts.
New reporting elements include account type classification, joint account details, and controlling person roles for investment entities that are legal arrangements. The legislation also refines advance tax ruling exchange requirements, raising thresholds for individual-related rulings to €1.5 million and excluding certain withholding tax opinions.
Pillar Two Reporting
The law introduces standardized reporting forms for multinational enterprise groups and large domestic groups with annual consolidated revenue of at least €750 million. Groups must file Income Inclusion Rule information returns within 15 months of the fiscal year-end, with an 18-month deadline for the first fiscal year.
The legislation establishes detailed information exchange procedures for Pillar Two implementation, including jurisdictional allocation of supplementary tax information and coordination mechanisms between tax authorities for corrections and compliance.
Context
These changes align Croatia with EU Directive 2023/2226 on CARF implementation and Directive 2025/872 on enhanced administrative cooperation. The comprehensive framework positions Croatia at the forefront of international tax transparency initiatives, particularly for digital assets, while strengthening existing automatic exchange mechanisms critical for combating tax evasion and ensuring proper taxation of multinational enterprises.