Grace Period for Compliance in Croatia

The Croatian Tax Authority announced that, during the initial phase of implementing the Fiscalization Act, it will apply the principle of opportuneness and refrain from initiating misdemeanor proceedings for early technical or operational difficulties in issuing or fiscalizing eInvoices. However, mandatory eReporting obligations remain fully in force—including the reporting of payments and rejected eInvoices—while rejection reporting by recipients (by the 20th of the following month) is treated as a formal waiver of the right to deduct input VAT.

The Croatian Tax Authority has announced that it will apply the principle of opportuneness during the initial phase of the implementation of the Fiscalization Act, meaning that misdemeanor proceedings will not be initiated in cases of initial difficulties related to the exchange and fiscalization of eInvoices.

According to the notice published on the Tax Authority’s website, this approach will apply in situations such as eInvoices not being issued as required or cases where one or both parties failed to fiscalize an eInvoice due to technical or operational challenges.

At the same time, the Tax Authority has issued additional clarifications regarding the obligation to issue and receive eInvoices, the arising of VAT liability, and the rules governing the right to deduct input VAT.

eReporting Obligations Still Apply

Despite the announced leniency, taxpayers are reminded that the Fiscalization Act formally introduced eReporting as a mandatory process. Through eReporting, data on certain supplies, as well as information on eInvoice payments and rejections, must be submitted to the Fiscalization System in accordance with the law.

A key element of this system is the eInvoice status, which allows:

• eInvoice issuers to verify whether an invoice has been received or rejected by the recipient, and
• eInvoice recipients to see whether the issuer has reported payment information.

Rejection of eInvoices and VAT Implications

Under Article 52 of the Fiscalization Act, recipients of eInvoices are required to report rejected eInvoices to the Fiscalization System by the 20th day of the month following the month in which the rejection occurred. The report must also include the reason for rejection.

The Tax Authority emphasizes that submitting rejection data is considered a formal statement that the recipient will not exercise the right to deduct input VAT for the rejected eInvoice.

Where applicable, issuers may cancel the rejected eInvoice and issue a new one, in line with standard commercial and tax practice.