Serbia: Interest on loans between related parties

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

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


Serbia: Interest on loans between related parties

babic.jpg

Filip Babic

According to the new bylaw on interest rates considered to be adhering to the arm's-length principle (published in the Official Gazette RS 17/2014), new interest rates have been prescribed with regards to related party financing transactions. These rates will be used to calculate interest income and interest expense arising from loans provided to or from related parties. The proposed rates are applicable to loans in RSD (Serbian dinar) and loans indexed in foreign currencies such as EUR, USD and CHF.

To determine the appropriate interest rate that should be charged on loans between related parties, taxpayers may choose one of the following options:

  • Use the general regulations regarding transfer pricing with one of the methods used to calculate interest rate; or

  • Use the interest rates prescribed by the Ministry of Finance.

The method chosen by the taxpayer should be applied consistently to all loans provided to or from related parties.

The interest rates prescribed by the Ministry of Finance and considered to be at arm's-length are shown in the box below.

Interest rates prescribed by the Ministry of Finance considered to be at arm’s-length

For banks

3.30% on EUR loans and RSD loans indexed in EUR

2.88% on USD loans and RSD loans indexed in USD

2.21% on CHF loans and RSD loans indexed in CHF

For other taxpayers

17.11% on short term loans in RSD

14.73% on long term loans in RSD

7.88% on short term loans in EUR and RSD loans indexed in EUR

6.55% on long term loans in EUR and RSD loans indexed in EUR

9.25% on short term loans in CHF and RSD loans indexed in CHF

6.30% on long term loans in CHF and RSD loans indexed in CHF

7.57% on short term loans in USD and RSD loans indexed in USD

5.56% on long term loans in USD and RSD loans indexed in USD


If the use of the loan agreement-defined interest rate for one transaction with a related party is chosen, the taxpayer has to use the same method for all transactions. By the same token, if a taxpayer chooses to use the arm's-length interest rate, then that approach has to be used for all transactions.

Despite the aggressive approach of the Serbian tax authorities with regards to related party financing transactions, non-resident group companies may still opt to grant loans instead of equity contributions to their Serbian subsidiaries to take advantage of the beneficial provisions of double tax agreements between Serbia and the relevant states. For example, according to the double tax treaties concluded between Serbia and Germany, France, Norway, the Netherlands, Finland and Sweden a 0% withholding tax rate is imposed on interest payments abroad whereas a withholding tax rate ranging from 5% to 15% may be suffered on dividend payments.

In addition, according to the Serbian thin capitalisation rules, interest expense and other related expenses are allowed as deductible provided that the loans obtained from related parties do not exceed four times the net equity of the company (10 times for banks and leasing companies).

Filip Babic (filip.babic@eurofast.eu)

Eurofast Global, Belgrade office

Tel: +381 11 3241 484

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

One of the two appointments is EY’s Gordon McIntosh, who becomes the big four firm’s second senior tax departure in September
Balson's move from a Tier 1 practice to a Tier 3 competitor looks counterintuitive. The market data suggests it is anything but
Awards
It was another banner year for Deloitte, which picked up more awards than any other firm at a gala ceremony held at The Londoner in Leicester Square
The big four firm has been embroiled in a scandal over partners’ misuse of confidential board papers to pitch for and win corporate audits for Westpac and Dexus
Drawing on lessons from the PepsiCo case, tax lawyer Paul McNab explains why the ATO's latest royalty guidance should concern multinationals well beyond the technology sector
As pillar two exposes the limits of fragmented tax processes, organisations are rethinking their operating models to create the trusted data foundations that AI demands
World Tax data shows Matt Donnelly is moving from a Tier 3 transactional tax practice to a Tier 1 market leader, underlining Kirkland & Ellis’s pull at the top end of the market
Nexdigm's Maulik Doshi and infer360 co-founder Sunil Agarwal dig deeper into their partnership and discuss why the tax technology industry is consolidating
Advisers won’t be short of work in a world of increased valuation disputes, documentation requirements and behavioural responses from clients seeking to protect their wealth
Jaydeep Menon explains how Frazier & Deeter built a specialist practice which helps UK start-ups expand into the US and why private equity backing is accelerating its ambitions
Gift this article