Croatia publishes ratification of US income-tax treaty and protocol

The Croatian Parliament adopted the law on 25 September. Article 1 confirms the convention signed on 7 December 2022 and the amending protocol signed on 28 April 2026. The package would be the countries’ first bilateral income-tax treaty. Its US transmittal describes reduced investment-income withholding and anti-treaty-shopping rules, not benefits already in force.^[1][2]

Notification, then application

Convention Article 29 requires each state to notify the other in writing through diplomatic channels after completing its procedures. Entry into force occurs on the later notification. Withholding provisions then apply to amounts paid or credited from the first day of the second following month; other taxes generally follow for tax years beginning from the next 1 January. The 2026 protocol enters into force with the convention.^[1]

The ratification law’s Article 5 expressly states that the instruments are not in force on the law’s commencement and that their entry into force will be separately published. The law itself commences on the eighth day after Gazette publication. That domestic rule is not the convention’s bilateral notification mechanism.^[1]

What groups should monitor

The protocol changes the limitation-on-benefits definition of active business, US double-tax-relief provisions and non-discrimination wording. Groups should monitor completion notices and tax-specific application dates before reviewing affected payments against the consolidated text. Croatian or US presence alone establishes neither entitlement nor a new filing deadline; this publication supports monitoring, not a current company-level relief determination.^[1]