All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

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


more across site & bottom lb ros

More from across our site

This week Brazil’s former President Luiz Inacio Lula da Silva came out in support of uniting Brazil’s consumption taxes into one VAT regime, while the US Senate approved a corporate minimum tax rate.
The Dutch TP decree marks a turn in the Netherlands as the country aligns its tax policies with OECD standards over claims it is a tax haven.
Gorka Echevarria talks to reporter Siqalane Taho about how inflation, e-invoicing and technology are affecting the laser printing firm in a post-COVID world.
Tax directors have called on companies to better secure their data as they generate ever-increasing amounts of information due to greater government scrutiny.
Incoming amendments to the treaty could increase costs on non-resident Indian service providers.
Experts say the proposed minimum tax does not align with the OECD’s pillar two regime and risks other countries pulling out.
The Malawian government has targeted US gemstone miner Columbia Gem House, while Amgen has successfully consolidated two separate tax disputes with the Internal Revenue Service.
ITR's latest quarterly PDF is now live, leading on the rise of tax technology.
ITR is delighted to reveal all the shortlisted firms, teams, and practitioners for the 2022 Americas Tax Awards – winners to be announced on September 22
‘Care’ is the operative word as HMRC seeks to clamp down on transfer pricing breaches next year.
We use cookies to provide a personalized site experience.
By continuing to use & browse the site you agree to our Privacy Policy.
I agree