Page 47 - Mazars Central and Eastern European tax guide 2023

Serbia fertilizer, etc.) and there is VAT-exemption for exports, In Serbia, resident individuals are taxed based on their
worldwide income, while non-residents are taxed only
transport and other services that are associated with the
importation of goods. Taxpayers with revenue in excess on income in Serbia. There is a flat rate of 10% for gross
of approximately EUR 68,000 must register for VAT salaries. Capital gains are taxed at 15%. Furthermore, the
purposes. Non-residents may register for VAT purposes tax rate on income from agriculture and forestry is 10%.
only through a tax representative. Income from the letting of real estate is taxable at 20%,
Mazars d.o.o. Beograd but before that, the gross basis is reduced by standardized
Bulevar Milutina Milankovica 7đ, The other indirect tax type in Serbia is excise duty. costs equalling 25%. The tax rate on income from royalties
Serbia and other intellectual property amounts to 20%.
Phone: (00381) 63 244 276 Personal income tax / Social security system
Fax: (00381) 63 293 102 In Serbia, resident individuals are taxed based on their Active incomes fall under the scope of the SSC system:
www.mazars.rs social contributions on behalf of employee are 19.90%
worldwide income, while non-residents are taxed only of the gross salary. These include contributions for
on income in Serbia. There is a flat rate of 10% for gross pension and disability insurance (14%), health insurance
salaries. Capital gains are taxed at 15%. Furthermore, the (5.15%) and unemployment insurance (0.75%).
tax rate on income from agriculture and forestry is 10%. Contributions on behalf of employer amount to 16.15%
Income from the letting of real estate is taxable at 20%,
Corporate taxes and other direct taxes A withholding tax at a rate of 20% is applicable but before that, the gross basis is reduced by standardized and include contributions for pension and disability
on dividends, interests, capital gains, royalties and costs equalling 25%. The tax rate on income from royalties insurance at 10% rate and health insurance (5,15%).
There is a flat 15% general corporate income tax rate. Tax other intellectual property rights, income from rent and other intellectual property amounts to 20%. There is no unemployment insurance payable on behalf
is levied on both resident and non-resident companies. of immovable and movable property and income from of employer. Personal deductions are applicable.
Resident companies are taxed on their worldwide income, specific services such as market research, accounting,
and non-residents are taxed only on income generated audit and other services related to business and legal
Average wage
in Serbia. The tax base is the pre-tax profit modified consulting. There is also a tax rate of 25% applicable Wage related taxes in Serbia Minimum wage in private sector
by several increasing and decreasing items. Capital gains to revenues realized by non-resident legal persons
are also included in the annual corporate profits tax from jurisdictions with a preferential tax system. Serbia Exchange rate RSD/EUR 117.4 in EUR in RSD in EUR in RSD
return. Losses can be carried forward for 5 years while the has a wide international treaty network with more than Non-taxable amount 185 21,712 185 21,712
carry back of losses is not permitted. There are several 60 double tax treaties. 345 40,480 884 103,797
tax deductions available on investments in relation
to the number of employed persons and investment Transactions between related parties must Total wage cost 536 115.15% 1,018 115.15%
funds, investing into the capital of newly incorporated be at arm’s length. The comparable uncontrolled price Social contribution tax 70 0 134 15.15%
companies performing innovative activities, and income method may be used, but in the absence of this method, Gross salary 466 100.00% 884 100.00%
from the use of deposited IP rights. Serbia applies thin taxpayers can use the cost-plus, the resale price method,
capitalisation ratios 4:1 (10:1 for banks). There is also the profit-sharing method or the net profit method. There Personal income tax 28 6.03% 70 7.91%
a requirement that interest paid to a non-resident must is an obligation to enclose transfer pricing documentation Employees' contributions 93 19.90% 176 19.90%
be on arm’s length terms. with the annual tax returns. Net salary* 345 74.07% 638 72.19%
A transfer tax of 2.5% is applied to transfers listed * Net salary differs on monthly basis approximately +/- 15 EUR.
Transfer pricing in Serbia in the Property Tax Act. There is no surtax or alternative
Arm’s length principle ü Since 2013 minimum taxes.
Since 2013, transfer pricing
Documentation liability ü documentation is submitted VAT and other indirect taxes
along with the CIT return.
The general rate is 20%, reduced rates are 10% (e.g.,
APA No – bread, milk, accommodation services, medications,
Country-by-Country Tax resident that is the ultimate
liability ü parent entity of an MNE.
VAT options in
Master file-local file Applicable / limits
(OECD BEPS 13) No – Serbia
applicable Distance selling No
Penalty Call-off stock ü
lack of documentation ü ~ EUR 16,900 for missing VAT group registration No
documentation
30% on tax underpayment + Cash accounting – yearly
tax shortage ü late payment interest amount in EUR (approx.) approx. EUR 405,000/year
Direct or indirect control Import VAT deferment No
or common managing director,
Related parties 25% < close family members, Sale of secondary raw materials and
non-resident entities from Local reverse charge services that are directly related to these
tax havens. goods, transactions of construction
buildings, and construction work.
Interest as described
in the Governmental Rulebook, Option for taxation Pere Mioč
Safe harbours ü transactions (other than letting of real estate No Partner, Tax Advisory Services
financial) below EUR 68,000
are not subject to TP rules. supply of used real estate No Phone: +385 (0)1 4864 424
Level of attention paid by Tax VAT registration approx. EUR 68,000/ Mobile: +385 (0)99 736 8746
Authority 8/10 threshold past 12 months E-mail: pere.mioc@mazars.hr

46 Mazars Central and Eastern European tax guide 2023 Central and Eastern European tax guide 2023 Mazars 47