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Croatia digital nomad visa and tax

brescape

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Sep 21, 2020
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Hi,
from 1st Jan 2021, Croatia it has introduced a 12 residency permit for business owner (called digital nomads in the regulation), or in another words for "digital nomad is a third-country national who is employed or performs work through communication technology for a company or his own company that is not registered in the Republic of Croatia and does not perform work or provide services to employers in the Republic of Croatia."

The new rule come with a, on the paper, very good tax benefit, as it provides an exemption of income tax for people that digital nomad but it doesn't eneter into details of other tax consideration.

Is there anybody that is familiar with it, in particular:

- Does the tax exception also applies to other sort of income, like for example rental income from property not located in Croatia
- One of the requirement of the legislation is to have a company. Most entrepreneur pay themselves as dividend. Is such dividend part of the 0% tax income in Croatia (obviously you may still be subject of withholding in the country where the company is resident)
- Being the setup such as you have a foreign company and you are tax resident, probably the biggest question here is that usually such setup would incur PE for the company in such country (Croatia), so the company could be considered tax resident in Croatia and pay taxes also in Croatia (according to the Double Tax Treaty between Croatia and the country of incorporation). Moreover it could open to exit taxes in the incorporation country. Does the law say anything about that, or do you have any idea about what are the general guidelines for this? I guess this could be the biggest deal breaker for anybody that has such setup, that is pretty much everybody given that this is a requirement for the digital nomad visa itself.

I looked online but could not find any more specific information
 
No-one is familiar with it because as you said, it's operative from the 1st January. I understand there are cities you can go to in Croatia and apply for this visa and they will give you a blank look. So even the basics are still getting shaken out. Check back in a couple of years, or if you're feeling brave, go and be a guinea pig.
 
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Completely useless.

The max duration of your stay cannot exceed 12 months and the visa cannot be renewed (why???) until a period of 6 months has passed. You have 90 days to leave the country after it expires.

In order to get the visa, you'll have to provide a work contract (in case you're officially employed somewhere) or a certificate of registration of your own company if you are a freelancer.

However, the CIT Act clearly states that a company is tax resident in Croatia if its place of effective management and control of business is in Croatia.

As far as I know this isn't being enforced yet as a lot of Croatian tax residents have companies in the UK, Estonia, etc. without nominee directors and get away with it. So basically like Cyprus.
 
3 months of visa, 12 month of digital nomad visa + 3 month to leave the country can make you tax resident in Croatia, potentially with a vey low tax liability, in a white listed EU country .
For many people that have no tax residence, it could be a good way to have a total legitimate tax residency, granted for two years, of being totally compliant rather than having the doubt if their native country will ever try to make you tax resident. I agree is not clear, but it seems a rather straight forward procedure compared to Cyprus and Portugal.
Moreover I think the corporate tax in Croatia is lower than UK and Estonia, so the double tax agreement between the country should not result in an increased tax liability, although I agree with some complication like exit tax, and just increased paperwork. So I would not say useless, unless you think Portugal and Cyprus have useless non dom regimes (albeit for longer period than 2 years)
 
I agree is not clear, but it seems a rather straight forward procedure compared to Cyprus and Portugal.
Seems a bold claim to make given how much more well-known and well-established as options Cyprus and Portugal are. Can’t remember Croatia ever being described as a fiscal paradise.
 
My comment is about the process, that _seems to be_ simpler than at least NHR Portugal and Non Dom Cyprus (when it requires a local company).
About the tax regime, it is all to be clarified or seen, that is pretty much the point of this thread