Page 30 - CEE Tax Guide 2025
P. 30

Kosovo


                           Forvis Mazars Kosova sh.p.k
                           Rr. Bekim Fehmiu, Icon
                           Tower, Pristina
                           Phone: +383 44 900 558
                           www.forvismazars.com/al










           Corporate taxes and other direct taxes              to corporate income tax, withholding tax applies and
                                                               is offset against the annual tax return.
           Resident companies are taxed on their worldwide
            income, while non-residents are taxed only         Transfer pricing (TP) regulations, effective from
           on income from Kosovo sources. Kosovo’s Corporate   2017, govern pricing between affiliated entities with
           Income Tax (CIT) follows worldwide taxation         at least 50% ownership or voting rights. Taxpayers
           principles. The annual turnover threshold for CIT   engaging in controlled transactions above EUR
            has been reduced from EUR 50,000 to EUR 30,000.    300,000 annually must submit a form by March
           Companies or sole traders with gross income         31 of the following year. The rules apply only to cross-
           above EUR 30,000 must pay CIT, while those below    border transactions, with safe harbors allowing a 7%
           can choose a special quarterly payment. The CIT     profit markup on low value-adding services without
           rate is 10%, paid quarterly. Taxable income is the   a transfer pricing study.
           difference between gross income and allowable
           deductions, with the tax period being the calendar   VAT and other indirect taxes
           year. Losses can be carried forward for six years.
                                                               In Kosovo, VAT applies to goods or services supplied
           Withholding tax applies to income from interest,    for payment by a taxable person and on imported
           royalties, rents, and games of chance for both      goods. A taxable person is anyone independently
           residents and non-residents. All income, except rent   carrying out economic activities. Exports are
           (9%), is taxed at 10%. Even if the recipient is subject   exempt from VAT, with input VAT deductions
                                                               allowed. VAT on imports is collected at the border

            Transfer pricing in Kosovo                         based on customs value and duties. The VAT rate
                                                               is 18% standard and 8% reduced, excluding exempt
            Arm’s length principle    Since 2017               or export supplies.

            Documentation liability   Since 2017               No other indirect tax are applicable.
            APA                       Since 2017
                                                                VAT options in Kosovo  Applicable / limits
            Country-by-Country        From FY 2017
            liability                 (with transitional rules).  Distance selling   No
            Master file-local file    From FY 2018 on.          Call-off stock       No
            (OECD BEPS 13)
            applicable                                          VAT group registration  No

            Penalty                                             Cash accounting – yearly   No
                                                                amount in EUR (approx.)
            lack of documentation     A maximum of EUR 2,500.   Import VAT deferment

            tax shortage        N.A.  N.A.                      Local reverse charge  Supply of construction and
                                                                                     construction-related works;
            Related parties     50% <  Direct or indirect                            construction activities.
                                      control or common
                                      managing director.        Option for taxation

            Safe harbors              Low value-added           letting of real estate
                                      services: mark-
                                      up to a maximum 7%.       supply of used real estate  No

            Level of attention paid   9/10                      VAT registration     EUR 30,000/year
            by Tax Authority                                    threshold

           Central and Eastern European tax guide 2025                                     Forvis Mazars    30
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