Form 5472 for Croatia Residents with a US LLC

A Croatia-resident owner of a US single-member LLC must file Form 5472 with a pro forma Form 1120 for every year the LLC had a reportable transaction with them. The US-Croatia income tax treaty signed on 7 December 2022 is not yet in force, and your Croatian OIB goes in the FTIN box.

Croatia has two populations of US-LLC owners: Croatian residents — developers in Zagreb, agency owners in Split, consultants and ecommerce operators who form Wyoming, Delaware or New Mexico LLCs for Stripe, PayPal and US banking — and remote workers on Croatia's digital-nomad temporary stay.

Both file the same US information return. Two features of the Croatian position change the mechanics compared with a UK or Indian owner: the treaty most online content treats as live is not in force, and the OIB that Croatia issues every person it monitors fills the box that troubles owners in zero-tax jurisdictions. Neither removes the obligation.

Rather have it done than explained? We prepare and fax the complete package from $149.

Do Croatia residents have to file Form 5472?

Yes, on the same terms as any other non-US owner. Three conditions:

1. The LLC is a US disregarded entity — a single-member LLC that has not elected corporate treatment.
2. Its sole member is a non-US person: not a US citizen, green card holder or US tax resident.
3. There was at least one reportable transaction during the tax year between the LLC and its owner or another foreign related party.

Under Treasury Regulation section 1.6038A-1, for tax years beginning on or after 1 January 2017 and ending on or after 13 December 2017, a foreign-owned US disregarded entity is treated as a corporation separate from its owner solely for the section 6038A reporting rules. That treatment takes no notice of where you live or what permit you hold.

Reportable transactions are money, property or services moving between you and your own LLC. Customer revenue is not reportable. A Stripe payout from a client never goes on the form; a transfer from that balance to your personal Zagrebačka banka account does.

The IRS Instructions for Form 5472 state that a $25,000 penalty may apply for failure to file when due and in the prescribed manner, for a substantially incomplete Form 5472, or for failure to maintain required records — and that a substantially incomplete form constitutes a failure to file. It is not automatic for every mistake.

Does the US-Croatia tax treaty change anything?

No — because there is no US-Croatia income tax treaty in force, and the signed treaty is not a substitute for one.

This is the fact most content about Croatia gets wrong.

Croatia is not on the IRS list. The IRS's United States income tax treaties A to Z page lists the treaties in force. Read by alphabetical section, the C entries are Canada, Chile, China, Cyprus and the Czech Republic. Croatia is absent.

A treaty was signed. Treasury announced on 7 December 2022 that the United States and Croatia had signed a comprehensive income tax treaty, the first between them. That announcement states the treaty "will enter into force after the United States and Croatia have notified each other that they have completed their requisite domestic procedures, which in the case of the United States refers to the advice and consent to ratification by the U.S. Senate."

That step has not happened. On 28 April 2026 Treasury announced a protocol amending the 2022 treaty, to be transmitted "as a package with the 2022 tax treaty to the U.S. Senate for that body's advice and consent to ratification." That package reached the Senate on 14 September 2026 as Treaty Doc. 119-2. Transmission is not ratification, and a treaty still awaiting the Senate is a treaty not in force.

A signed treaty that has not entered into force gives a taxpayer nothing: no article to invoke, no reduced rate, no competent authority, no treaty-based return position. Because that can change once the Senate acts, check the IRS A-to-Z page yourself in a later year.

What the absence of a treaty in force does and does not change:

Every component of the Form 5472 package sits in the "no change" rows. The removed items matter only to owners with US-source passive income or US-based operations, who should take advice on US taxability.

What goes in the FTIN box if you have a Croatian OIB?

Enter your OIB. Porezna uprava, the Croatian Tax Administration, describes the personal identification number (OIB) as a permanent identification of every person, used by public authorities in official records and for the international exchange of information. It is the number the tax authority holds you under — what the FTIN box asks for.

An OIB goes to Croatian citizens at birth or on naturalisation, to legal persons established in Croatia, and to foreign persons where there is a cause for monitoring them: a tax liability, assets acquired in Croatia, registration in an official record, or the foreigner's own request.

Three traps. A company's OIB is not your personal OIB — keep a Croatian d.o.o.'s number out of your FTIN box. A permit holder with no OIB and no tax number anywhere writes "None" and relies on the reference ID, covered in our FTIN and reference ID guide. And do not get a US ITIN just to fill this box — see do I need an ITIN.

Use your actual Croatian address in Part II, not the LLC's US registered agent address.

Does Croatian tax affect the US filing?

No. Croatian personal income tax and Form 5472 run on separate tracks, and neither filing satisfies the other.

In outline only: Porezna uprava's page on the determination of residency status explains that under the General Tax Act a resident is a natural person with a permanent or habitual residence in Croatia. Permanent residence turns on owning or possessing a dwelling for at least 183 days in one or two calendar years, actual occupancy not required; habitual residence means a continuous or time-linked stay of at least 183 days over the same period. Residents are taxed on the world income principle. How Croatia treats your LLC's profits is a question for Porezna uprava or a Croatian adviser; we do not advise on it.

On the permit: the Ministry of the Interior's page on the temporary stay of digital nomads defines a digital nomad as a third-country national who is employed or performs work through communication technology for a company or his own company not registered in Croatia, and who does not perform work or provide services to employers in Croatia. Temporary stay is granted for up to 18 months, with an extension of up to six months where less was granted, and a new application only six months after the previous stay expired.

That permit changes nothing about Form 5472, and it does not settle your Croatian tax position either — the immigration page says nothing about tax at all.

How does a Croatia-based owner actually file?

You cannot e-file; the package goes to the IRS by fax or mail.

1. Prepare the pro forma Form 1120 with "Foreign-owned U.S. DE" across the top of page 1. Only the DE's name and address and items B and E are required.
2. Prepare Form 5472 — Part I for the LLC, Part II for you with your Croatian address, OIB and reference ID, Part III for the related party, Part IV for monetary transactions, and a Part V statement itemising contributions and distributions.
3. Convert euro to US dollars at a reasonable rate for each transaction date, applied consistently, stating the basis in Part V.
4. Sign the pro forma Form 1120.
5. Fax to 855-887-7737, or mail to Internal Revenue Service, 1973 Rulon White Blvd, M/S 6112, Attn: PIN Unit, Ogden, UT 84201.
6. Keep the timestamped fax receipt. It is transmission evidence, not IRS acceptance.

The due date for a calendar-year entity is generally 15 April; Form 7004 extends it under the special disregarded-entity instructions. See our deadline guide and extension guide.

Getting it filed from Croatia

A treaty signed but not in force, an OIB in the FTIN box, euro conversion with a stated basis, a Croatian company as a second related party — each is how a self-prepared form ends up substantially incomplete.

Form5472 Prep prepares Form 5472, the pro forma Form 1120 and the Part V statement, has a qualified tax accountant review it, faxes it to the IRS Ogden PIN Unit and returns the timestamped receipt. Late years include a reasonable cause cover letter.

$149 standard, ready in 5-7 business days. $199 express, within 3 business days. +$99 per additional past tax year. IRS fax delivery included.

We are not a CPA firm and do not give tax advice, in the US or in Croatia. We prepare and submit the US information return.

Start your filing — about 15 minutes. See full pricing.

Frequently asked questions

Is there a US-Croatia tax treaty I can rely on?

Not yet. A treaty was signed on 7 December 2022 and a protocol amending it on 28 April 2026, but the package still awaits the US Senate's advice and consent to ratification. Croatia is not on the IRS list of treaties in force.

Does the missing treaty mean I can skip Form 5472?

No. Form 5472 is required by US domestic law under section 6038A. Treaties allocate taxing rights over income; none exempts anyone from this information return. Treaty and non-treaty owners file identical packages.

What FTIN do I enter as a Croatian resident?

Your OIB, the personal identification number assigned by Porezna uprava. Add a self-assigned reference ID number on line 4b(2), identical every year. Do not use a Croatian company's OIB as your personal FTIN.

I hold Croatia's digital-nomad temporary stay. Does that change my filing?

No. The permit governs where you may stay and work, not your US information-return obligation. If your LLC had a reportable transaction with you, Form 5472 is due.

I have no OIB and no tax number anywhere. What then?

Write "None" in the FTIN block rather than leaving it blank, and rely on a self-assigned reference ID. Our FTIN and reference ID guide covers the edge cases, including owners with no settled address.

My LLC received EUR 90,000 from clients and I paid myself EUR 40,000. What is reportable?

The EUR 40,000 you paid yourself, converted to US dollars. The client revenue is not a related-party transaction. See reportable transaction examples.

I have never filed and my LLC is three years old. What now?

File every outstanding year promptly with a reasonable cause statement, before the IRS writes to you. Each year carries its own exposure. See our late filing guide.

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A signed treaty is not a treaty you can use. Until the Senate acts, a Croatia-based owner stands exactly where an owner in a no-treaty country stands — which changes nothing about the filing.

File from Croatia in about 15 minutes, or compare a no-treaty jurisdiction in our UAE and Dubai guide. Splitting the year across countries? The guide for digital nomads covers filing with no single tax residence.

Educational content only; not tax or legal advice.