Mazars Cinotti Consulting d.o.o.
10000 – Zagreb, Pile I br. 1., Croatia
Phone: (00385) 1 4864 420
Fax: (00385) 1 4864 429

Kristijan CINOTTI

Partner – Advisory services
Phone: (00385) 1 4864 420
Mobile: (00385) 99 4877 112


Corporate tax and other direct taxes

The general corporate income tax rate is flat and amounts to 15%. Tax is applied to both resident and non-resident companies. Resident companies are taxed on their worldwide income, and non-residents are taxed only on income generated in Serbia. The tax base is the pre-tax profit modified by several increasing and decreasing items. Also, capital gains are included in the annual corporate profits tax return. Losses can be carried forward for 5 years while the carry back of losses is not permitted. There are several tax deductions available on investments in relation to the number of employed persons and investment funds. Serbia applies thin capitalization ratios 4:1 (10:1 for banks). Also, there is a requirement that interests paid to a non-resident must be on arm’s length terms.

A withholding tax at the rate of 20% is applicable on dividends, interests, capital gains, royalties and other intellectual property rights, income from rent of immovable and movable property and income from services used in Serbia. Also, there is tax rate of 25% applicable to revenues realized by non-resident legal persons from jurisdictions with a preferential tax system. Serbia has a wide international treaty network with more than 50 double tax treaties.

Transfer pricing is a relatively new topic in Serbia. Transactions between related parties must be at arm’s length. The comparable uncontrolled price method may be used, but in the absence of this method, the taxpayer may use the cost-plus, the resale price method, the profit sharing method or the net profit method. There is an obligation to enclose transfer pricing documentation with the annual tax returns.

The transfer tax of 2.5% is applied on transfers listed in the Property Tax Act. There is no surtax or alternative minimum taxes.

Transfer pricing in Serbia
Arm’s length principle since 2013
Documentation liability since 2013, prepare and submit transfer pricing documentation together with the
CIT return
Hyerarchy in TP methods   Follows OECD TP Guidelines
Lack of documentation ~ EUR 16,200 for missing documentation
Tax shortage 30% on tax underpayment + late payment interest
Related parties 25%
direct or indirect control
or common managing director, close family members, non-resident entities from tax havens
Safe harbours Interest as described in Governmental Rulebook, transactions (other than financial) below EUR 65.000 are not subject to TP rules

Level of attention paid by Tax Authority:


VAT and other indirect taxes

The general rate is 20%, reduced rates are 10% (e.g. bread, milk, accommodation services, medications, fertilizer, etc.) and VAT-exemption for exports, transport and other services which are associated with the importation of goods. Taxpayers with revenue in excess of approximately EUR 65,000 must register for VAT purposes. Non-residents may register for VAT purposes only through a tax representative.

The options/limits based on the Serbian VAT Act are as follows:

Other indirect tax type in Serbia is excise duty.

VAT Options in Serbia
Distance selling
Call-off stock
VAT group registration
Cash accounting approx EUR 405,000/year
Import VAT deferment
Local reverse charge sale of secondary raw materials and services that are directly related to these goods, transactions of construction buildings, construction work
Option for taxation
- letting of real estate
- supply of used real estate
VAT registration threshold approx EUR 65,000/past 12 months

Personal income tax / Social security system

In Serbia, resident individuals are taxed based on their worldwide income, while non-residents are taxed only on income in Serbia. There is a flat rate of 10% for gross salaries. Capital gains are taxed at 15%. Furthermore, the tax rate on income from agriculture and forestry is 10%. Income from the letting of real estate is taxable at 20%, but before that, the gross basis is reduced by standardized costs equalling 25%. The tax rate on income from royalties and other intellectual property amounts to 20%. Active incomes fall under the scope of the SSC system: individual social contributions are 19.90% of the gross salary. These include contributions for pension and disability insurance (14%), health insurance (5.15%) and unemployment insurance (0.75%). Employers contributions amounts 17.90%. Only difference is that contributions for pension and disability insurance are 12% (2% less than employee’s obligation). Personal deductions are applicable.

The examples below show the cost of the employer and the employee in case of minimum wage level and the average wage in the private sector:

Wage-related taxes in Serbia Minimum wage Average wage in private sector
Exchange rate RSD / EUR 123.1179 in EUR in RSD in EUR in RSD
Non-taxable amount 94 11 604 94 11 604
  247 30 463 516 63 474
TOTAL WAGE COST 292 117.90% 608 117.90%
Social Contribution tax0 44 17.90% 92 17.90%
GROSS SALARY 247 100.00% 516 100.00%
Personal income tax 15 6.19% 42 8.17%
Employee’s contributions 49 19.90% 103 19.90%
NET SALARY* 183 73.91% 371 71.93%

*Net salary differs on monthly basis approximately +/- 15 EUR

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