Global

Details

  • Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 7/22/2013

Serbia - Transfer pricing documentation rules, methods in new “rulebook” 

July 22:  Transfer pricing provisions enacted in Serbia are effective July 2013, following the enactment and publication of a “rulebook” on transfer pricing.

The “rulebook” (as these transfer pricing rules are referred to in Serbian law) provides guidance for determining the method to apply in determining related-party transactions under the arm’s length principle. The rulebook is intended to clarify certain tax issues in Serbia—given that transfer pricing has become a significant tax issue in Serbia.


The transfer pricing rulebook was enacted and then subsequently published in the official gazette in early July 2013, and thus, has an expected effective date of 20 July 2013.


In general, the transfer pricing rulebook:


  • Establishes the form and content of transfer pricing documentation
  • Provides five methods—comparable uncontrolled price, resale price, cost plus, transactional net margin, and profit split methods—for use by taxpayers in determining arm’s length prices

The method selected generally is to be based on the particular circumstances of each taxpayer’s situation.


With new rulebook, transfer pricing documentation will become an integral part of accompanying documentation that is required with a taxpayer’s corporate income tax return.


Read a July 2013 report [PDF 133 KB] prepared by the KPMG member firm in Serbia: Rulebook on transfer pricing and methods applies for determining prices in related-party transactions in accordance with the arm’s length principle has been enacted



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




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