• Service: Tax, Global Transfer Pricing Services
  • Type: Regulatory update
  • Date: 2/11/2014

Serbia - Relief from documentation for certain “less important” transactions 

February 11:  Amendments to Serbia’s “rulebook” on transfer pricing concern transactions that, because of their value, are deemed as not having a material effect on the taxpayer’s tax liability.

The amendments specifically repeal a requirement for taxpayers to prepare a detailed analysis showing compliance with the arm’s length principle for these “less important” transactions—thus, providing relief to taxpayers from the transfer pricing documentation rules for these transactions.

Instead, taxpayers may apply a simplified approach for including these “less important” transactions in the transfer pricing documentation by simply presenting the information in a short report.

Transactions that may be excluded from the detailed analysis documentation rules are those that satisfy at least one of two conditions:

  • The transaction with the related party is a one-off transaction in the year for which the tax balance sheet is submitted, and the transaction’s value does not exceed RSD 8 million (approximately U.S. $94,000); or
  • The total value of all transactions with the related party in the year for which the tax balance is submitted is not greater than RSD 8 million.

This relief, however, is not available for loans and credit transactions.

The amendments were published in the official gazette (no. 8/2014, 29 January 2014) and have an effective date of 30 January 2014.

Read a February 2014 report [PDF 182 KB] prepared by the KPMG member firm in Serbia: Rulebook on transfer pricing amended

Contact a tax professional with KPMG's Global Transfer Pricing Services.

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