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2013-2014 Eur. Tax Stud. 1 (2013-2014)

handle is hein.journals/eurotaxs5 and id is 1 raw text is: European Tax Studies Tendencies in Croatian Tax Law regarding CFC Legislation1 Sime Jozipovic2 1. Introduction After a long and intense accession process, the Republic of Croatia recently became the twenty-eighth member state of the EU3. Following a wide- ranging reform process in all relevant areas, Croatia finally reached an acceptable level of harmonization with the acquis communautaire.4 One of the key areas in the accession process was the area of international (primary inter-European) taxation. Many recent cases have revealed that even long-established member states sometimes have trouble harmonizing their tax law with the rules of European law. This especially applies to the complex structure of international tax law.5 Despite the fact that Croatian tax law was heavily influenced by the German, Austrian and other EU tax systems, its international tax regulations, especially in the area of measures against tax avoidance, partially diverge from these systems. This is particularly apparent with regard to CFC legislation, which is in many European countries highly developed6 and fiscally relevant, but in Croatia rather neglected. 1 How to quote this article: Jozipovi6, S., Tendencies in Croatian Tax Law Regarding CFC Legislation, in European Tax Studies, 2013, No. 1, (ste.seast.org/en), pp. 1-19. 2 ime Jozipovi6 Mag. Iur., LLM ger. (LMU M nchen) Researcher at the Max Planck Institute for Tax Law and Public Finance, contact: simejozipovic@hotmail.com 3 Art. 3 Sub. 3. Treaty of accession of the Republic of Croatia to the European Union, Official Gazette of the Republic of Croatia - Narodne Novine (NN) 2/12. http://eur- lex.eu ropa.eu/en/treaties/new-2-46. htm 4 For information on the results of the EU accession negotiations with Croatia compiled by the Directorate General for Enlargement - European Commission from November 2011, see: http://ec.europa.eu/croatia/index hr. htm 5 For example, in the area analysed here: eCJ f. 12. 9. 2006, C-196/04, Cadbury Schweppes. 6 See Wissenschaftlichen Beirat Steuern der Ernst & Young GmbH: Hinzurechnungsbesteuerung und gesonderte Feststellung von Besteuerungsgrundlagen IStR 2013, 549 fn. 5 refering to IBFD, European Tax Handbook, 2012. © Copyright Seast - All rights reserved 1/2013

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