Tax authorities issued FAQ’s on E-Invoicing

Who Is Considered an Issuer or Recipient of e‑Invoices?

Under the law, e‑invoice issuers and recipients include:

• All Croatian tax‑liable entities, such as VAT‑registered taxpayers, corporate income taxpayers, and self‑employed income taxpayers with business presence in Croatia.
• Public sector bodies, including government ministries, state administration bodies, local units, and all budgetary and extra‑budgetary users registered in the official state register.

However, not every taxpayer is automatically both an issuer and recipient. For example, a VAT‑registered entity that is not subject to personal income tax or corporate income tax may not be subject to fiscalization in final consumption but is still required to issue and receive e‑invoices for B2B purposes.

Entities NOT Considered Issuers or Recipients

The following do not fall under the definition of e‑invoice issuers/recipients:

• Branches of foreign companies registered in Croatia
• Fixed establishments of foreign companies that only hold a Croatian VAT ID without being locally registered
• Foreign companies with only a Croatian VAT number and no permanent establishment

Issuing e‑Invoices in Practice

For all taxpayers required to issue e‑invoices, the law mandates structured electronic invoices compliant with Croatia’s technical specifications.

A relevant example:

• Self‑employed artists in the VAT system must issue an e‑invoice when billing a taxpayer that qualifies as an e‑invoice recipient under the law. Any legally required pension and health contributions can be shown in the “Notes” field of the e‑invoice, as permitted by the expanded technical schema.

Key Takeaway

The Croatian Tax Administration emphasizes the importance of correctly determining one’s status (issuer/recipient) and complying with the structured electronic invoicing requirements. As Croatia moves toward full B2B e‑invoicing under Fiscalization 2.0, understanding these definitions is essential for businesses adapting their systems and processes.

Briefing Document & Podcast: Croatia – E-Invoicing, E-Reporting, and E-Transport – VATupdate