Serbia: An overview of transfer pricing in Serbia

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Serbia: An overview of transfer pricing in Serbia

sagianni.jpg

Anastasia Sagianni

For some multinationals operating in Serbia in 2013 it was not the first year of implementation of the transfer pricing rules. The law governing this area has been present in Serbia for more than a decade. More specifically, transfer pricing rules have been present since July 1 2001, but the Serbian Rulebook that was enacted on July 2013 gave clarity to the country's transfer pricing rules. Nonetheless, multinational companies operating in Serbia already had their transfer pricing policies in place due mainly to the fact that their headquarters were in countries with established transfer pricing rules. For the large majority of entities, 2014 was the first year of implementation regarding transactions that took place during 2013. For those entities the procedure was demanding both for their financial departments and their advisers.

Is there a 'right' or 'wrong' way to prepare a transfer pricing study?

The application of the arm's-length principle requires the ability to see the nature of each inter-company transaction by understanding also under what circumstances those transactions took place, interpreting comparable situations and applying judgment. Moreover, since transfer pricing is not an exact science, there is no right or wrong but there are some risky areas where taxpayers should be very careful. For example, by saying merely that the applied margin is in accordance with the group's policy you do not document that the transaction is in accordance with the arm's-length principle. Also by preparing a transfer pricing study which does not include a justification for the selected TP method you may face a pitfall because in a potential transfer pricing audit tax authorities in Serbia may have another opinion about the selected method.

Anastasia Sagianni (anastasia.sagianni@eurofast.eu)

Eurofast Global, Belgrade office

Tel: +381 11 3241 484

Website: www.eurofast.eu

more across site & bottom lb ros

More from across our site

India’s budget changes goods and services tax rules; UK private school VAT challenge fast-tracked
It is understood that the US has vowed to oppose any outcome from talks taking place at the UN
It’s the second year in a row that RSM’s tax business has posted fee income growth above 10%
Recent guidance from the Indian tax authorities should provide confidence for investors, says Sanjay Sanghvi of Khaitan & Co
Grant Wardell-Johnson also suggests there could be solutions to the friction between the US and the OECD when it comes to pillar two
The president had so far avoided announcing tariffs on the US’s neighbours despite previous threats
The firm brought in three managing directors from EY and Deloitte in Europe; in other news, KPMG’s bid to practise law in US was delayed
One expert argues the ERS would be unlikely to improve taxpayers’ experience unless it comes with additional funding to hire more agents and staff
From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025
Holland & Knight, Nelson Mullins and McCarter & English made the joint-most tax partner hires in the US last year, according to annual ITR Talent Tracker data
Gift this article