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Croatia: Related-party loans, interest rate increase for 2016

Related-party interest rate in Croatia

The Ministry of Finance on 23 December 2015 announced the interest rate for loans between related parties will be 5.14% per annum, effective 1 January 2016.


Related content

Accordingly, as of 1 January 2016:

  • The maximum corporate profit tax deductible interest rate on loans from a Croatian tax non-resident to a Croatian tax resident related party increases from 3% per annum to 5.14% per annum.
  • The minimum corporate profit tax acceptable interest rate on loans from a Croatian tax resident to a Croatian tax non-resident related party also increases from 3% per annum to 5.14% per annum.

These measures also apply to loans between two Croatian tax residents if one of them is in a "favorable tax position."

KPMG observation

All entities using related-party financing need to review their current loan structures and, if appropriate, take immediate action.


Read a December 2015 report [PDF 119 KB] (in both Croatia / English) prepared by the KPMG member firm in Croatia: Kamatne stope između povezanih osoba / Related-party interest rate

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