Transfer Pricing Documentation

Transfer Pricing Documentation

In Serbia, taxpayers must prepare and submit transfer pricing documentation along with their Corporate Income Tax (CIT) return within 180 days after the fiscal year ends. This documentation, which must be in the Serbian language, should encompass all intercompany transactions, both domestic and cross-border. Additionally, transactions with companies located in tax havens are treated as intercompany transactions.

To support the figures in the CIT assessment form, an annual analysis of a taxpayer's transfer pricing position is necessary. Since the taxpayer holds the burden of proof, developing appropriate analysis and detailed transfer pricing documentation is crucial to demonstrate the arm's length nature of related party transactions.

Our Approach

We assist in preparing comprehensive documentation that aligns with the Serbian CIT Law requirements while incorporating best international and OECD practices. Our services cater to those who:

  • Seek high quality transfer pricing documentation aligned with best international practices and domestic legislation;

  • Desire assurance that related party transactions are thoroughly analyzed and documented as per local requirements;

  • Seek documentation consistent with both group approach and local compliance requirements; or

  • Want to identify the risk areas related to transfer pricing documentation or gaps therein.

transfer pricing documentation

Our services:

  • Preparation of transfer pricing documentation in accordance with local legislation; 

  • Localisation of group-level transfer pricing documentation (Master file, Local file templates) to prepare a transfer pricing report that would satisfy local requirements, while remaining consistent with group methodologies and templates;

  • Review of group-level or internally prepared transfer pricing documentation against local standards;

  • Streamlined process of development of robust, globally coordinated transfer pricing documentation for the whole group for domestic multinational enterprises.

Benefits:

  • Achieving consistent and regulatory-compliant transfer pricing documentation.

  • Establishing quality transfer pricing documentation as a robust first line of defense in potential audits.

Contact us

Dragan Draca

Dragan Draca

Partner, Tax Services, PwC Serbia

Mirjana Petkov

Mirjana Petkov

Director, Transfer Pricing Services, PwC Serbia

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