​​​​​AGREEMENTS FOR THE AVOIDANCE OF DOUBLE TAXATION

​Agreements which the Republic of Croatia has concluded and assumed that apply: 

1     If the beneficial owner is a company which holds directly at least 25% of the capital of the company paying the dividends 

2     If the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends 

3     If the beneficial owner is a company which holds directly or indirectly at least 10% of the capital of the company paying the dividends 

4     Where the dividends are paid by a company which is a resident of Croatia to a resident of Malta who is the beneficial owner thereof, the Croatian tax so charged shall not exceed 5% of the gross amount of the dividends 

5     If the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the voting power of the company paying the dividends 

6     If the beneficial owner is a company which holds directly at least 25% of the capital of the company paying the dividends (this share should be at least 100.000 US $ 

7     If the beneficial owner is a company which holds directly at least 20% of the capital of the company paying the dividends 

8     If the  dividends are paid to a company that has the capital of which is wholly or partly divided into shares, as long as it holds directly at least 25% of the capital of the company paying the dividends 

9     When the beneficial owner is a company which holds directly at least 10% of the capital of the company paying the dividends where that latter company is a resident of Israel and the dividends are paid out of profits which are subject to tax in Israel at a rate which is lower than the normal rate of Israeli company tax 

10   When the beneficial  owner is a company (other than a partnership)  which  holds directly  at  least  25% of the capital of  the company paying the dividends and has invested to  the capital of that company at least  150.000 Euros 

11   If the beneficial owner is a company which is a resident of the other Contracting State and controls, directly or indirectly, at least 25% of the capital of the company paying the dividends (other than where the dividends are paid by an investment vehicle as mentioned in subparagraph (b)) 

12   When those dividends are paid out of income (including gains) derived directly or indirectly from immovable property within the meaning of Article 6 by   an    investment vehicle which distributes most of this income annually and whose income from such immovable property is exempted from tax

13  Dividends which are deductible in computing the taxable income of the company paying the dividends in the Contracting State of which that company is a resident may be taxed in that Contracting State according to the laws of that Contracting State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed 10 per cent of the gross amount of the dividends

14 If the beneficial owner is a company (other than a partnership) which holds directly at least (20) per cent of the capital of the company paying the dividends throughout a 365 day period that includes the day of the payment of the dividend (for the purpose of computing that period, no account shall be taken of changes of ownership that would directly result from a corporate reorganisation, such as a merger or divisive reorganisation, of the company that holds the shares or that pays the dividend)

15 The application date for the Republic of Croatia is 01.01.2025; due to the difference between the calendar year and the fiscal year, the application date for Hong Kong is 01.04.2025.

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