Home / Articles / Transfer pricing deadline in Serbia
Transfer pricing deadline in Serbia
When the transfer pricing report is due, who must file, when a short-form report is enough and how to prepare on time.
Pročitajte ovu stranicu na srpskom →
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 period | Deadline for PDP and transfer pricing report |
|---|---|
| Calendar year 2025 | 29 June 2026 |
| Calendar year 2026 | 29 June 2027 |
| Fiscal year other than calendar | 180 days after the last day of the fiscal year |
| Status change, liquidation, bankruptcy | With 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 report | Full study | |
|---|---|---|
| When | Total transactions with one related party up to RSD 8,000,000 per year, or a one-off transaction up to that amount | Above RSD 8,000,000, 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 |
Recommended timeline
- 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 PDP with the transfer pricing report via ePorezi.
- 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.
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.