1.     Introduction

In a world where global companies operate seamlessly across borders and skilled workers, managers, and trainees become key resources for growth and competitiveness, the institute of intra-corporate transfer (ICT) represents one of the most important mechanisms of business mobility. As a member of the European Union, Croatia has aligned its legislation with European standards, enabling an efficient and legally secure pathway for the temporary employment of highly qualified foreign workers within international corporations. An intra-corporate transfer, also known as ICT or an ICT permit (hereinafter: ICT permit), is a temporary assignment for professional purposes or training of a third-country national employed by a company established outside the EEA, who has an employment contract with an entity established in the Republic of Croatia that belongs to the same company or corporate group. When applicable, ICT also includes mobility between entities established in an EEA Member State, under the conditions prescribed by the Aliens Act (Official Gazette Nos. 133/2020, 114/2022, 151/2022, 40/2025) (hereinafter: the Act). ICT permit enable temporary residence and work in Croatia without the need for a “traditional” work permit, allowing employers fast and efficient mobility of key personnel within a corporate group. What further enhances the attractiveness of this residence basis is the fact that family members of the transferee may also obtain temporary residence in the Republic of Croatia for the purpose of family reunification, pursuant to Article 57 (1) (1) of the Act. This ensures not only the preservation of family life, but also full economic integration of the family. At the same time, foreign professionals and managers are provided with security that mobility within a corporate group will not negatively impact their personal or professional lives.

This article provides an overview of the key requirements, application procedure, validity periods, and benefits of the ICT permit in the Republic of Croatia, with an emphasis on long-term and short-term mobility, as well as practical implications for employers and employees.

2.     ICT Permit Holders in Croatia – Managers, Specialists and Trainees

One of the residence options in the Republic of Croatia is a combined residence and work permit for an intra-corporate transfer, commonly referred to as an ICT permit. A third-country national who is transferred within a company is a person performing duties as a manager, specialist, or trainee and who has an employment contract with a company, branch, or representative office established in a third country, which temporarily transfers them for professional purposes or training to a company, branch, or representative office established in the Republic of Croatia (hereinafter: the entity) belonging to the same company or corporate group.

Pursuant to Article 116(2) of the Act, an intra-corporate transferee is:

Manager – a person in a senior position who manages the business operations of the entity established in the Republic of Croatia and who is under general supervision or receives instructions from the management or shareholders of the company, or from a person holding an equivalent position. This role includes managing the entity or one of its departments, supervising and controlling the work of other supervisory, professional, or managerial staff, and having authority to make decisions regarding employment rights and obligations;
Specialist – a person possessing competences essential to the field of activity, techniques, or management of the entity established in the Republic of Croatia. When assessing competence, consideration is given not only to knowledge specific to the entity, but also to any special expertise demonstrated through professional qualifications, including relevant work experience for the type of work or activity requiring specific technical knowledge, as well as possible membership in a recognized professional association; or
Trainee – a person holding a higher education diploma who has been transferred to the entity established in the Republic of Croatia for career development or participation in training in business techniques or methods, and who is remunerated for the duration of such transfer.
3.      Validity Period of the ICT Permit

In the Republic of Croatia, an ICT permit may be issued for a maximum period of three years for managers and specialists (provided that the manager or specialist has been employed within the same company or corporate group for an uninterrupted period of at least nine months immediately prior to the transfer), and for one year for trainees (who must have been employed within the same company or corporate group for at least six consecutive months immediately prior to the transfer). After the expiry of the maximum transfer duration as outlined above, a new application for approval of a residence and work permit for an intra-corporate transferee may only be submitted after a six-month period has elapsed (the so-called “cooling-off period”).

However, a solution still exists that allows ICT permit holders to remain in Croatia. They are not necessarily required to leave the country after the maximum transfer period has ended — they have the possibility to apply for the continuation of their stay in Croatia on another legal basis (for example, for other purposes, as digital nomads, for work and residence on different grounds, for study purposes, etc.).

4.    Residence and Work Permit for Intra-Corporate Transfer

For an ICT permit, there is no requirement to conduct a labour market test pursuant to Article 98 of the Act, nor to obtain a prior positive opinion from the Croatian Employment Service under Article 99 of the Act — which makes this residence procedure significantly faster and simpler. This means that the application for an ICT permit is submitted directly to the Ministry through the competent police administration or police station.

The Ministry, through the competent police administration, will issue an ICT permit to a third-country national who meets the conditions under Article 59 of the Act, as well as the following requirements:

the entity established in the Republic of Croatia and the company established in a third country belong to the same company or corporate group
the transferee is a manager or specialist who has been employed within the same company or corporate group for an uninterrupted period of at least nine months immediately prior to the transfer, or at least six months in the case of a trainee
the employment contract and a transfer letter are submitted, indicating: details concerning the duration of the transfer and the location of one or more entities; proof that the transferee will assume a managerial, specialist, or trainee role in one or more entities; salary and other employment conditions ensured during the intra-corporate transfer; and proof that, upon completion of the transfer, the transferee may return to the company, branch, or representative office established in the third country. The employment contract and transfer letter must also clearly demonstrate guaranteed working conditions, including: maximum working hours and minimum rest periods, minimum paid annual leave, increased salary for overtime work, statutory health and safety protection, non-discrimination provisions, and mandatory protective measures for pregnant workers, workers who have recently given birth or are breastfeeding, and young workers. These working conditions must be guaranteed at a level consistent with the legislation of the Republic of Croatia or any collective agreement extended to all employers and workers in a specific sector or geographic area.
the manager or specialist holds the necessary qualifications and experience to perform work in the entity established in the Republic of Croatia, while a trainee holds a higher education diploma
the salary provided is not lower than that of employees in the Republic of Croatia performing comparable work in accordance with applicable laws or collective agreements
the primary purpose of establishing the entity in the Republic of Croatia is not to facilitate the regulation of residence of intra-corporate transferees
the duration of the intra-corporate transfer does not exceed three years for managers and specialists, or one year for trainees.
In the event that the conditions under which the ICT permit was granted cease to exist, both the employer and the intra-corporate transferee must notify the competent police administration or police station within 15 days of the change in circumstances.

The Ministry, through the competent police administration, shall reject an ICT permit application if the submitted documentation has been fraudulently obtained or falsified, if the employer fails to comply with obligations related to social security, workers’ rights, working conditions and employment, and tax obligations in accordance with Croatian regulations and any applicable collective agreement; if bankruptcy or liquidation proceedings have been initiated against the employer; or if the employer does not perform an economic activity. An appeal against the decision rejecting the ICT permit is not permitted, but an administrative dispute may be initiated before the competent administrative court within 30 days.

5.         Conditions for the Re-Assignment to Croatia of a Person Already Working in Europe Under an ICT Permit

A third-country national holding a valid ICT permit issued by another EEA Member State may work in an entity established in the Republic of Croatia that belongs to the same company or corporate group for up to 90 days in any 180-day period (the so-called short-term mobility under Article 119 of the Act), without the obligation to obtain a residence and work permit or a work registration certificate.

A third-country national holding a valid intra-corporate transferee permit issued by another EEA Member State who intends to work for more than 90 days in an entity established in the Republic of Croatia that belongs to the same company or corporate group may be granted a residence and work permit for long-term mobility (Article 120 of the Act). The application for a residence and work permit for long-term mobility is submitted to the police administration or police station according to the place of residence, or to a diplomatic mission or consular office of the Republic of Croatia.

The third-country national may continue working in the Republic of Croatia while the application is pending, provided that the application was submitted before the expiry of the short-term stay and they hold a valid intra-corporate transferee permit issued by another EEA Member State. If the conditions under which the permit for long-term mobility was issued cease to exist, both the employer and the third-country national are obliged to notify the competent police administration or police station within 15 days of the occurrence of such circumstances.

The Ministry shall designate a contact point responsible for receiving and forwarding information electronically concerning the issuance and extension of permits for long-term mobility, as well as decisions requiring third-country nationals to leave the Republic of Croatia. The application for long-term mobility may be refused if the documentation is falsified, if the worker does not meet the prescribed requirements, if the duration of the transfer exceeds the statutory limits (three years for managers and specialists, one year for trainees), or if the previous permit expired during the procedure. An appeal against a refusal decision is not permitted; however, an administrative dispute may be initiated before the competent administrative court.

The Ministry shall submit statistical data to the European Commission on the number of residence and work permits issued to intra-corporate transferees and on long-term mobility permits issued for the first time, as well as on permits extended, revoked, or annulled. Statistical data shall be disaggregated by nationality, validity period of the permits, economic sector, and the position of the transferees.

6.    Rights of Intra-Corporate Transferees

ICT permit holders are granted equal treatment with Croatian nationals in relation to participation in strikes and industrial action, the freedom of trade union organisation and membership in trade unions or any professional organisation, as well as the rights and benefits provided by such organisations, including the right to collective bargaining and conclusion of collective agreements, recognition of diplomas, certificates and other professional qualifications, access to goods and services and the provision of goods and services available to the public, except for procedures relating to access to housing as prescribed by special regulations, without prejudice to the freedom of contract under EU and national law, and services provided by public employment offices. Accordingly, ICT permit holders exercise their rights in accordance with the legislation of the Republic of Croatia and any collective agreement binding the employer, if applicable, governing the areas listed above.

What further enhances the attractiveness of this residence basis is the fact that family members of intra-corporate transferees may obtain temporary residence in the Republic of Croatia for the purpose of family reunification under Article 57(1)(1) of the Act. This ensures not only family unity but also full economic integration of family members, as they are granted the right to work and self-employment under the conditions prescribed by the Act. This element makes the intra-corporate transfer scheme particularly competitive compared to other residence categories, as it provides foreign professionals and managers with the assurance that mobility within the corporate group will not adversely affect their family or professional life.

7.    Conclusion

The ICT permit in Croatia represents an efficient and flexible instrument for the transfer of professionals within international corporate groups. It enables the swift engagement of key personnel in local business operations, facilitating the transfer of knowledge and expertise while ensuring compliance with workers’ rights and legal regulations.

Croatia, as an attractive destination for business activities and innovation, offers professionals a secure legal framework, competitive working conditions, and opportunities for professional development in an international environment. For both employers and employees, the ICT permit provides a practical framework for organizing international mobility, while Croatia benefits from the opportunity to develop competencies, strengthen the labour market, and create a favourable business environment that encourages the arrival of highly qualified experts from third countries.

 

LEGAL SOURCE:

·       Aliens Act (“Official Gazette” Nos. 133/20, 114/22, 151/22, 40/25)

 

Author:

Jelena Nađ, Attorney-at-Law, Partner
LAW FIRM JURŠETIĆ & ALEKSOVSKI Ltd.