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Transfer pricing rules in Serbia
Serbia applies the arm's-length principle under the Corporate Income Tax Law and a dedicated Rulebook that follows the OECD Transfer Pricing Guidelines. Any Serbian taxpayer with related-party transactions must file a transfer pricing report with its annual tax return, within 180 days of year end — 29 June for a calendar year.
Related parties include shareholders with 25% or more, entities under common control, and counterparties in low-tax jurisdictions. Domestic related-party transactions are covered as well as cross-border ones.
Full study or short-form report
| Short-form report | Full study (local file) | |
|---|---|---|
| When | Total transactions with one related party up to RSD 8 million per year, or a one-off transaction up to that amount | Above RSD 8 million, and always for loans and credits |
| Content | Description, value, counterparty | Group and industry analysis, functional analysis, method selection, comparability analysis, arm's-length conclusion |
| Lead time | Days | 2–6 weeks depending on the number of transactions and data availability |
What we do for international groups
- Serbian local file built on your group master file and transfer pricing policy.
- Benchmarking of intra-group services, distribution margins, royalties and loan interest.
- Tax base adjustment calculation and reporting on the PDP return where prices deviate from arm's length.
- Intercompany agreement review so pricing is set at arm's length upfront, not corrected afterwards.
- Tax audit support — representation and documentation during a Serbian Tax Administration review.
Recommended timeline for a calendar-year subsidiary
- January–February: inventory of all related-party transactions for the prior year; collection of agreements and invoices.
- March: method selection per transaction and benchmarking data.
- April–May: drafting the study, reconciliation with statutory accounts, any tax base adjustment.
- By 29 June: filing of the PDP return with the transfer pricing report via the ePorezi portal.
Read a case study of a four-entity group whose intercompany pricing we restructured.
Frequently asked questions
When is transfer pricing documentation due in Serbia?
The transfer pricing report is filed together with the corporate income tax return, within 180 days of the end of the tax period. For companies with a calendar fiscal year that is 29 June of the following year.
Who must prepare transfer pricing documentation?
Every Serbian corporate income tax payer that had transactions with related parties during the tax period — foreign or domestic, including loans. The value of transactions only determines whether a full study or a short-form report is filed.
What is a related party under Serbian rules?
An entity that directly or indirectly holds at least 25% of the shares or voting rights, entities under common control, and any counterparty resident in a jurisdiction with a preferential tax system, regardless of ownership.
Is a short-form report ever enough?
Yes, for transactions with a single related party whose total annual value does not exceed RSD 8 million (roughly EUR 68,000), and for one-off transactions up to that amount. Loans and credits always require a full analysis.
Which methods are accepted?
The five OECD methods: comparable uncontrolled price, resale price, cost plus, transactional net margin and profit split. Serbian rules follow the OECD Guidelines closely; interest on related-party loans may alternatively be benchmarked against the arm's-length rates published annually by the Ministry of Finance.
Can you work with our group's master file?
Yes. We build the Serbian local file on your existing master file and group policy, align it with Serbian formal requirements and the PDP return, and coordinate with your group tax team in English.
Have a Serbian subsidiary with related-party transactions?
Email us the outline — we will tell you within two business days what the documentation involves and how long it takes — every group is different, so we quote only after a free review of your transactions.