BDK Advokati/Attorneys at Law

Serbia: tax — amendments to the Transfer Pricing Rulebook

In its Newsletter 17/2013, BDK presented novelties introduced into Serbian transfer pricing regulations by the new Rulebook on Transfer Pricing and Arm’s Length Methods Applicable to Determination of Prices in Transactions Between Related Entities (‘Rulebook’), which elaborates on the statutory requirement for mandatory transfer pricing documentation for fiscal year 2013 and onwards.

On 29 January 2014, the Ministry of Finance adopted amendments to the Rulebook aimed at easing certain transfer pricing requirements and rectifying certain ambiguities and technical errors. The most important amendments pertain to the following: abbreviated form of the transfer pricing report; content of functional and group analysis; definition of internal comparable uncontrolled price; and definition of the term related entity for the purpose of the application of the certain transfer pricing methods.

The amended Rulebook allows for submission of an abbreviated report that does not have to contain analysis as to whether the transfer prices are in conformity with the arm’s-length principle, in the following cases…

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