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The Dominant Client Is Not Proof of a Hidden Employment Relationship

paušalci IT
paušalci IT / Image by: foto Shutterstock

In the early stages of tax reform, faced with a decline in the number of trades, the Tax Administration recognized the need to encourage the development of small entrepreneurs, especially craftsmen, who independently carry out economic activities. Support for self-employment was prepared, and tax regulations were adjusted to increase the number of independent activities as much as possible. After all these measures, the number of independent activities, especially those that took advantage of the flat-rate taxation option, suddenly increased, raising concerns that these tax benefits were being used contrary to the purpose of the law, namely to pay less tax. As a result, tax regulations were readjusted to prohibit the use of tax benefits contrary to the purpose of the law, and the characteristics of dependent work (employment relationship) were defined.

Correction of the Law

The Tax Law stipulates that a person who benefits from tax advantages by using the tax system through organizational forms that are taxed at lower prescribed tax rates, which were not intended for a specific group of taxpayers, will be considered to be using tax benefits contrary to the purpose of the law.

One of the cases mentioned in the regulation is one in which the payer of income for work that has the characteristics of dependent work contracts with the taxpayer other ways to perform the work or uses organizational forms that are taxed at lower tax rates (flat-rate crafts). The law further stipulates that if it is determined that the flat-rate craft is actually a hidden workplace, that craftsman will be considered responsible for paying taxes and contributions as if it were an employment relationship, and the client of the work (‘hidden employer’) will be liable for those public contributions as a guarantor payer.

When a Hidden Employment Relationship Exists

To claim that something is a hidden employment relationship, its characteristics must be precisely determined. They are categorized into three categories, and the characteristics of the employment relationship are determined based on the fulfillment of three criteria: behavioral control, financial control, and the relationship between the parties. Behavioral control encompasses facts that show whether the employer has the right to direct and control what the employee does and how they perform the work by giving instructions, training, or other means; financial control encompasses facts that show whether the employer has the right to direct or control the financial and business aspects of the employee’s work; and the relationship between the parties encompasses facts that show the nature of the relationship between the parties.

The tax regulation defines that to determine the characteristics of dependent work, the integrity of the relationship between the payer of income and the taxpayer performing the work must be considered, taking into account all facts relevant for taxation and all elements of the characteristics of dependent work. An interesting provision of the tax regulation states that in determining the characteristics of dependent work, not all criteria of the characteristics of dependent work need to be fulfilled simultaneously. The characteristics of dependent work are determined by the decisive influence of behavioral control and/or financial control of the payer of income over the taxpayer performing the work and/or if the relationship between the parties indicates a decisive connection in the execution of the work.

Ruling of the High Administrative Court

After briefly recalling how this is defined by the tax regulation, we come to the case for which the High Administrative Court ruled in favor of the flat-rate craft (Usž-2668/2024-5, published on January 16, 2026). The case before the Court involved a person who, as part of a flat-rate craft, performed programming work for a company. This company was not the only client, but it was the most important client of the craft (over seventy percent of revenue). After the owner of the craft provided data on the business operations at the request of the Tax Administration, the Tax Administration considered it to be a hidden employment relationship and decided to charge the craftsman for unpaid taxes and contributions. The craftsman did not give up, and the case reached the High Administrative Court.

The Court decided that in this case, the criterion of financial control was not fully met because although the company was the majority payer, the craftsman at one point began collaborating with another company and continued significant collaboration with the latter after completing the project with the first company.

Furthermore, the Court assessed that the criterion of behavioral control was also not satisfied because although the client always set the final product and deadlines for execution, it could not be determined that the company had the legal ability to direct and control how the work was performed, whether by giving instructions, training, or in some other way. The criterion of the relationship between the parties was partially satisfied, but not completely, and the Court ultimately ruled that this case did not constitute a hidden employment relationship.

Thus, the Court decided that a dominant client alone is not proof of a hidden employment relationship, that certain criteria should not be viewed selectively, and that the relationship must be assessed as a whole. Whether this ruling will affect other cases in practice remains to be seen.

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