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Filing deadline

The transfer pricing report is filed together with the corporate income tax return (form PDP), within 180 days of the end of the tax period. For taxpayers with a calendar fiscal year that is 29 June of the following year.

Tax periodDeadline for PDP and transfer pricing report
Calendar year 202529 June 2026
Calendar year 202629 June 2027
Fiscal year other than calendar180 days after the last day of the fiscal year
Status change, liquidation, bankruptcyWith the tax return for the period up to the change

The report is filed electronically via the ePorezi portal as an attachment to the PDP return. A study kept on file but not attached to the return counts as not filed.

Who must file

Every Serbian corporate income tax payer with related-party transactions during the tax period. A related party is an entity holding directly or indirectly at least 25% of shares or voting rights, an entity under common control, and any counterparty in a jurisdiction with a preferential tax system regardless of ownership. Domestic related-party transactions are covered as well as cross-border ones.

Typical transactions: intra-group sales of goods and services, management fees, royalties and licence fees, loans and guarantees, leases and recharges.

Full study or short-form report

Short-form reportFull study
WhenTotal transactions with one related party up to RSD 8,000,000 per year, or a one-off transaction up to that amountAbove RSD 8,000,000, and always for loans and credits
ContentDescription, value, counterpartyGroup and industry analysis, functional analysis, method selection, comparability analysis, arm's-length conclusion
Lead timeDays2–6 weeks
  1. January–February: inventory of all related-party transactions for the prior year; collection of agreements and invoices.
  2. March: method selection per transaction and benchmarking data.
  3. April–May: drafting the study, reconciliation with statutory accounts, any tax base adjustment.
  4. By 29 June: filing of PDP with the transfer pricing report via ePorezi.
  5. During the year: set intercompany prices at arm's length upfront, so no adjustment is needed next year.

Frequently asked questions

Is a shareholder loan without interest a transfer pricing issue?

Yes. Loans between related parties always require a full analysis regardless of amount, and the interest is compared with the arm's-length rate published by the Ministry of Finance or established by analysis.

What is the penalty for not filing?

Failure to file the report with the tax return is a tax offence. In an audit, the Tax Administration may adjust the tax base, assess additional corporate tax, interest and penalties. The main exposure is the adjustment for the difference between the agreed price and the arm's-length price.

Can you build on our group master file?

Yes. We prepare the Serbian local file on your master file and group policy, align it with Serbian formal requirements and the PDP return, and coordinate with your group tax team in English.

Direct contact

Have related-party transactions in Serbia?

Send us the list — we tell you whether you need a full or short-form report and what the deadline is.

Call us+381 11 306 3028Mon–Fri 9–17 CET