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 2025

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

Corporate counsel should combine deep technical knowledge with strategic dynamism, says Agarwal, winner of ITR’s EMEA In-house Indirect Tax Leader of the Year award
Luxembourg’s reform agenda continues at pace in 2025, with targeted measures for start-ups and alternative investment funds
Veteran Elizabeth Arrendale will lead the new advisory practice, which will support clients with M&A tax structuring, post-deal integration, and more
MAP cases keep increasing, and cases closed aren’t keeping pace with the number started, the OECD’s Sriram Govind also told an ITR summit
Nobody likes paperwork or paying money, but the assertion that legal accreditation doesn’t offer value to firms and clients alike is false
Ryan hopes the buyout will help it expand into Asia and the Middle East; in other news, three German finance ministers have called for a suspension of pillar two
SKAT, which was represented by Pinsent Masons, had accused Sanjay Shah and other defendants of fraudulent dividend tax refund claims
TP managers must be able to explain technical issues in simple terms, ITR’s European Transfer Pricing Forum heard
Prudential had challenged HMRC over VAT group relief; in other news, Donald Trump unveiled timber and wood tariffs, and the European Commission published a ViDA implementation strategy
Australia’s CbCR rules have ‘widespread support’ and do not put American companies at a competitive disadvantage, the FACT Coalition said
Gift this article