Topic: Obligation to issue and fiscalized an invoice for Multisport cards acquired by employers “in the name and on behalf of employees”
Opinion date: 15 December 2025
1. Introduction
Many employers enable their employees to use Multisport cards, whereby the supplier’s invoice is
issued to the company, but the card is purchased in the name and on behalf of the employee. Such an
invoice constitutes a passthrough item: the company does not incur a cost, has no right to input VAT
deduction, and does not perform a supply of goods or services to the employee within the meaning of the Croatian VAT Act.
In practice, questions have emerged as to whether payroll deductions or benefits-in-kind related to Multisport cards are subject to fiscalization requirements.
2. Question Submitted to Ministry of Finance
The Croatian Chamber of Tax Advisers (HKPS) requested a written confirmation from the Ministry of
Finance acknowledging that, in this scenario, there is no obligation to issue an invoice to the employee
nor to perform fiscalization, given that—until now—the Ministry of Finance has only provided informal
oral guidance that no such obligation exists.
HKPS expressed the view that:
- the company does not supply any goods or services to the employee,
- there is no obligation to calculate VAT under the VAT Act,
- payroll deduction represents a passthrough item, and
- there is no legal basis for issuing an invoice to the employee.
3. Position of the Ministry of Finance
- In contrast to previous oral interpretations, the Ministry of Finance has now stated in its written opinion
that:
fiscalization requirement applies to taxpayers subject to corporate income tax or personal
income tax on self-employment - turnover in final consumption includes all invoices issued to end recipients (consumers)
- for fiscalization purposes, any supply to employees or any form of receivable from employees is treated as a B2C transaction
- therefore, if a fiscalization taxpayer supplies a good or service to an employee and charges for it (either through employee payment or payroll deduction), the taxpayer is required to issue an
invoice and fiscalized it.
According to this interpretation, the same could apply to other deductions, such as agreed payments
for voluntary pension insurance (third pillar), supplementary health insurance, and benefits in kind
(e.g., use of a company car for private purposes). This position leaves many questions open, so
further clarification is needed. We will inform later whether this applies to other deductions, but for
now, we can confirm that it is required for costs where the company has received an invoice (issued to
the company and deducted from the employee because the employee uses the service).
4. Alternative approaches to settling obligations with employees
Instead of issuing invoices and fiscalizing them, certain organizations are considering the following
models:
A. Transferring the obligation to the employee
The employee independently contracts and pays for the service or product directly to the supplier.
In this case, the employer does not participate in the payment process, does not issue an invoice to
the employee, and has no fiscalization obligation, as no transaction takes place between employer
and employee.
B. Full cost absorption by the employer
The employer covers the full cost and does not deduct the amount from the employee’s salary.
Such expenditure is treated as an employer’s cost (e.g. employee benefit) and is recorded accordingly
in the company’s books. As there is no B2C collection from the employee, no fiscalization requirement
arises.
However, as this constitutes a taxable benefit in kind, the employer must calculate personal income
tax and social security contributions, as the benefit is not taxexempt under the Personal Income Tax
Act.
5. Conclusion
Based on the issued opinion and established practice:
- A taxpayer subject to fiscalization who supplies a good or service in final consumption and charges the employee (whether through payment or payroll deduction) must issue an invoice and perform fiscalization.
- Alternative solutions are described above.
- We are awaiting an additional opinion regarding cases of benefits in kind, voluntary pension
insurance (third pillar), and supplementary health insurance. However, based on the current understanding, invoices should not be required to be issued for these types of deductions.
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Please note that legislation is subject to frequent change. This newsletter is therefore necessarily
based on our understanding and correct interpretation of the law and practice at the time of publication
of this newsletter. This newsletter will not be updated for changes in legislation that occur after the issuance of this newsletter.
Newsletter_Multisport_Interpretation of the Ministry of Finance on Multisport Cards and the Fiscalization Requirement
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