Can the personal income tax refund be paid to Revolut or Aircash?

The Tax Administration of the Republic of Croatia has published an opinion on a taxpayer’s request for a personal income tax refund on Revolut or Aircash. We transmit the opinion of the Tax Administration in its entirety.

Tax Administration Opinion

“If, in the process of determining the annual income tax, the difference between the overpaid income tax advance and the established annual liability tax administration determines, the overpaid tax can, by the provisions of Article 46, Paragraph 8 of the Income Tax Act (Official Gazette, No. 115/16, 106/18, 121/19, 32/20, 138/20, 151/22) to the taxpayer return without a separate written request.

Article 92, paragraph 1 of the Ordinance on income tax (Official Gazette, No. 10/17, 128/17, 106/18, 1/19, 80/19, 1/20, 74/20, 1/21, 102 /22, 112/22, 156/22, 1/23), it is prescribed that by Article 86 of the Law, state administration bodies and judicial authorities and other state bodies and services of local and regional (regional ) self-governments, institutes, non-profit organizations, entrepreneurs – legal and natural persons make payments of receipts to physical persons, to their account for payment by the regulation governing payment transactions with the bank, i.e. to non-residents on their account.

Paragraph 3 of the same article of the Ordinance stipulates that the Tax Administration will refund overpaid income tax and surcharges in non-cash to a payment account by the regulation governing payment transactions with banks that taxpayers have open with banks, and exceptionally in cash for taxpayers who do not have a bank account for payment, i.e. if a natural person does not have a current or giro account, i.e. if, at the time of the income tax return, he does not receive receipts for which there is an obligation to pay to the account.

Revolut Bank UAB

According to the notification of the Croatian National Bank dated June 1, 2022, Revolut Bank UAB was approved to expand its services in the Republic of Croatia, based on which it now provides services for opening and maintaining payment accounts such as current accounts or giro accounts in the Republic of Croatia. To the above, the Central Office of the Tax Administration published opinion CLASS:410-01/22-01/909, URBROJ:513-07-21-01-22-2, dated June 7, 2022, which you can read at the following link.

According to the above, the tax refund can be made to an account opened at Revolut Bank UAB.


Furthermore, according to the opinion of the Central Office of the Tax Administration CLASS: 10-01/19-01/2216, URBROJ:513-07-1-01-19-3 of December 23, 2019, digital institutions for electronic money are considered a particular type of provider payment services whose establishment and operations regulates the Law on Electronic Money (Official Gazette, No. 64/2018), and the payment of a worker’s salary to the kuna account of a digital institution for electronic money is not considered a payment to a bank account by the mentioned provisions of the Law and Ordinance. You can read the opinion at the following link.

By the above, and considering that Aircash d.o.o., Zagreb, has been registered in the Register of payment service providers and Electronic Money issuers since October 3, 2019, tax refunds cannot be made to the Aircash account.”

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