Page 48 - CEE Tax Guide 2025

Serbia

Forvis Mazars d.o.o. Beograd
Bulevar Milutina
Milankovica 7đ, Serbia
Phone: (00381) 63 244 276
www.forvismazars.com/rs

Corporate taxes and other direct taxes incorporated companies performing innovative
activities, and income from the use of deposited
There is a flat 15% general corporate income IP rights. Serbia applies a thin capitalization ratio
tax rate. Tax is levied on both resident and non- of 4:1 (10:1 for banks). There is also a requirement
resident companies. Resident companies are taxed that interest paid to a non-resident must
on their worldwide income, and non-residents are be on arm’s length terms.
taxed only on income generated in Serbia. The
tax base is the pre-tax profit modified by several A 20% withholding tax is applied to dividends,
increasing and decreasing items. Capital gains are interests, capital gains, royalties and other
also included in the tax return for annual corporate intellectual property rights, income from rent
profits. Losses can be carried forward for 5 years, of immovable and movable property, and income
but the carry back of losses is not permitted. There from specific services such as market research,
are several tax deductions available on investments accounting, auditing, and other services related
in relation to the number of employed persons and to business and legal consulting. There is also
investment funds, investing into the capital of newly a tax rate of 25% applicable to revenues realized
by non-resident legal persons from jurisdictions
with a preferential tax system. Serbia has a wide
Transfer pricing in Serbia
international treaty network with more than
Arm’s length principle Since 2013 60 double tax treaties.
Documentation liability Must be submitted in hard Transactions between related parties must
copy in local language. be at arm’s length. The comparable uncontrolled
APA No – price method may be used, but in the absence of this
method, taxpayers can use the cost-plus method,
Country-by-Country Tax resident that the resale price method, the profit-sharing method,
liability is the ultimate parent
entity of an MNE. or the net profit method. There is an obligation
to enclose transfer pricing documentation with the
Master file-local file No – annual tax returns.
(OECD BEPS
13) applicable
A transfer tax of 2.5% is applied to transfers
Penalty listed in the Property Tax Act. There is no surtax
or alternative minimum taxes.
lack of documentation Up to ~ EUR 16,900 for
missing documentation.
VAT and other indirect taxes
tax shortage 30%—40% on tax
underpayment + late The general rate is 20%, reduced rates are 10% (e.g.
payment interest bread, milk, accommodation services, medications,
Related parties 25% < Direct or indirect fertilizer, etc.) and VAT-exemption is provided for
control or common exports and for transport and other services that are
managing director, close associated with the importation of goods. Taxpayers
family members.
with revenue in excess of approximately EUR 68,000
Safe harbors Interest must register for VAT purposes. Non-residents
as described in the may register for VAT purposes only through a tax
Governmental Rulebook.
representative.
Level of attention paid 7/10
by Tax Authority The other indirect tax type in Serbia is excise duty.

Central and Eastern European tax guide 2025 Forvis Mazars 48