• Service: Tax, International Corporate Tax, Global Transfer Pricing Services, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 2/19/2014

Serbia - Prescribed interest rates for related-party financing  

February 19: Serbia’s Minister of Finance on 14 February 2014 adopted a “rulebook” (Pravilnik) with respect to arm’s length interest rates. The rulebook provides the prescribed interest rates applicable to related-party financing arrangements, and is applicable for taxpayers with related-party financing during 2013—i.e., the rulebook affects transfer pricing documentation for 2013.

The rulebook was published in the official gazette (No. 17/2014 (14 February 2014)).

Prescribed interest rates

According to the provisions of Articles 59, 60 and 61 of Serbia’s corporate income tax law, taxpayers can either use the interest rates prescribed by the Ministry of Finance or elect to apply other methods for a determination of arm’s length interest.

  • Taxpayers can elect to apply only one of these two methods—that is, the method that is selected must be applied consistently to all loans to / from related parties.
  • The prescribed interest rates apply to interest income / interest expenses incurred during 2013, regardless of the period from which loan(s) originate.
  • For banks and finance leasing companies, unlike other companies, a single interest rate for both short- and long-term borrowings / placements is prescribed.
  • The rulebook does not prescribe the interest rates for loans / placements in the Serbian dinar (RSD) made by banks and finance leasing companies to other banks and finance leasing companies.

The following table lists the interest rates prescribed in the rulebook.

Market interest rates as prescribed by the rulebook

Taxpayer RSD loans EUR loans and RSD loans denominated in EUR USD loans and RSD loans denominated in USD CHF loans and RSD loans denominated in CHF
Banks and financial leasing companies NA 3.30% 2.88% 2.21%
Other companies (short-term loans) 17.11% 7.88% 7.57% 9.25%
Other companies (long-term loans) 14.73% 6.55% 5.56% 6.30%

*CHF = Swiss francs, USD = U.S. dollar, EUR = euro

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