Serbia: An overview of transfer pricing in Serbia

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: 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 & shared bottom lb ros

More from across our site

The OECD may be making a mistake if a 2029 review is intended to outlast Trump in the hope of more favourable treatment from the US Democrats
Nexdigm has invested in Singapore-based infer360, a TP intelligence product designed by ex-PwC partners
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Americas Tax Awards
Despite initial hopes that the reporting obligation had been suspended, compliance challenges brought by Brazil’s indirect tax reform are very much a reality
As tax authorities embrace AI and governments weigh pillar two reforms, Latin America is developing a more connected and internationally focused tax agenda
Advisers with pre-existing corporation tax or self-assessment accounts must now register or risk enforcement action from HMRC
India's tax authorities are increasingly scrutinising the rationale behind cross-border structures
Sharmila Sanmugam's move from industry to WTS UK offers an early glimpse into how the fledgling firm hopes to compete with larger rivals
Historical claims involving KPMG Australia's tax practice have surfaced as the firm battles a separate parliamentary inquiry into its handling of whistleblowers
While AI is revolutionising tax work, it is also reshaping clients’ willingness to pay for advice and their perception of the value generated by tax advisers
Gift this article