2013-2014 European Tax Studies 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.
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