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Serbia: Rule book on transfer pricing



Jelana Janjic

Gordana Vucenovic

By amendments to the Law on Income Tax of Legal Entities on December 2012 (hereinafter: The Law), that will be applicable in the process of preparation of the tax balance for 2013, significant changes were made in the field of transfer pricing. The Official Gazette no. 61/2013 has published the rulebook on Transfer Pricing and Methods applicable for defining transaction prices between connected entities.

The below are the main issues in transfer pricing that are defined closer by the rulebook.

1) Form and content of the documentation on transfer pricing that is to be delivered to the Tax Administration, along with the tax balance, starting from 2013.

2) Choice and way of applying the method by principle out of reach for defining transaction prices between connected entities. According to Article 61 of the law, the following methods are applicable for defining the price of transaction by the principle out of reach:

  • Method of comparable market prices;

  • Method of cost plus a reasonable profit (cost plus gross margin method);

  • Resale price method;

  • Transactional net margin method; and

  • Profit sharing method.

3) Way of defining the base for calculation of depreciation of the fixed asset obtained from transaction with connected entity, in accordance to the Article 10a and Articles 59-61 of the law.

The access to control of transfer prices by the tax authorities, which represents the most delicate part of the tax legislation, is prescribed in the Article 9 on the rulebook.

Jelana Janjic ( and Gordana Vucenovic (

Eurofast Global, Belgrade Office, Serbia

Tel: +381 11 3241 484


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