Croatia has recently published the Law on Amendments to the Act on Administrative Cooperation in the Field of Taxation, marking an important regulatory change. This law, published in the Official Gazette in December 2025, implements two key EU directives: DAC8 and DAC9.
These amendments are critical for multinational groups with cross-border operations in the EU. They aim to enhance transparency in the cryptoasset sector and ensure that information related to Pillar Two taxation is automatically exchanged between EU member states.
Key Changes and Impact
What Has Changed?
- DAC8 Implementation: This directive mandates the automatic exchange of information regarding cryptoassets among EU member states. It aims to improve compliance, reduce tax evasion, and enhance financial transparency.
- DAC9 Implementation: This directive facilitates the exchange of information related to Pillar Two, allowing tax authorities in the EU to share tax data concerning multinational corporations’ tax rates and profits in real-time.
What Has Not Changed?
- Ongoing Compliance Requirements: The core compliance obligations for Transfer Pricing documentation remain unchanged. Companies must still ensure that they are maintaining comprehensive and defensible Transfer Pricing documentation, even with the introduction of these new reporting requirements.
- Audit and Documentation Standards: Tax authorities will continue to enforce high standards of documentation, and failure to provide this information when requested will still attract penalties.
Transfer Pricing Risk and Compliance
What This Means for Transfer Pricing Risk
- Risk Management Adjustments: The implementation of DAC8 and DAC9 increases the complexity of compliance for multinational groups operating in the EU. The automatic exchange of information related to cryptoassets and Pillar Two means that companies must be more diligent in their reporting and documentation practices to mitigate potential risks.
- Impact on Audits: Given the increased sharing of tax information, tax authorities will likely focus more on auditing companies’ compliance with EU-wide tax regulations.
- Penalties for Non-compliance: Non-compliance or failure to submit the required information for cryptoassets or Pillar Two may lead to fines or penalties, especially since authorities will now have direct access to this data.
Practical Implications for Multinational Groups
- Documentation Readiness: Companies must ensure that all cryptoasset transactions and Pillar Two data are well-documented and accessible for audits. Having up-to-date records on these areas is crucial for audit readiness.
- Internal Governance: Tax, legal, and finance teams must establish clear protocols to manage the increased volume of data and ensure that information can be easily accessed and shared in compliance with EU directives.
- Revised Policies: Multinational groups must review and update their internal policies to align with DAC8 and DAC9’s reporting and compliance requirements.
Broader Implications and Compliance Alignment
How This Fits into Croatia’s Broader Transfer Pricing Strategy
- Alignment with OECD Guidelines: Croatia’s implementation of DAC8 and DAC9 is part of a broader effort to align its tax reporting with international standards, including OECD Transfer Pricing guidelines and the EU’s commitment to combating base erosion and profit shifting (BEPS).
- Efficiency Gains: The law’s implementation streamlines the reporting process for multinational corporations operating in the EU, reducing the complexity of cross-border tax reporting.
- Trends in Transfer Pricing Regulations: These changes align with broader global tax transparency trends, including the increasing emphasis on reporting digital assets and automatic data exchanges among tax authorities.
Future Outlook: This regulatory change is just one of many steps toward greater tax transparency within the EU. Multinational groups will need to stay updated as further amendments or clarifications may come into play.
What Multinational Groups Should Do Now
Steps to Take Before Filing
- Review Transfer Pricing Studies: Ensure that all documentation, particularly related to cryptoassets and Pillar Two, is complete and aligns with the new reporting requirements.
- Prepare for New Reporting: Companies should review the DAC8 and DAC9 requirements in detail, confirming that their systems are capable of automatically exchanging information with other EU member states.
- Ensure Data Availability: Ensure that all necessary documentation regarding cryptoassets and Pillar Two data is ready for review by tax authorities.
How TransferPricing.report Supports Croatia Compliance
- Local File Preparation: TransferPricing.report can help multinational groups prepare Croatia-compliant Local Files, ensuring that they meet the country’s specific documentation standards.
- Transfer Pricing Documentation Review: We assist in reviewing and updating Transfer Pricing studies to ensure full compliance with DAC8 and DAC9’s new data exchange requirements.
- Audit-Readiness Support: TransferPricing.report helps multinational groups stay prepared for audits by keeping documentation aligned with EU requirements and ready for tax authority requests.
- Governance and Centralized Storage: TransferPricing.report can help in establishing centralized storage and governance processes for managing Transfer Pricing documentation.
Final Takeaway: Streamlined Reporting, Stronger Compliance
- Croatia’s adoption of DAC8 and DAC9 brings important changes to Transfer Pricing compliance, simplifying the filing process while maintaining robust reporting standards. Multinational groups need to ensure that they are fully prepared to comply with these new EU regulations.
- The automatic exchange of information demands that companies maintain clear, complete, and accessible documentation, particularly around cryptoassets and Pillar Two data.
This is general information only and not professional advice. Consult a professional before acting.