Ministry of Finance has published the Rulebook on arm’s length interest rates that are applicable for 2025.
According to the Serbian Corporate Income Tax (CIT) Law the arm’s length level of interest can be determined by using the interest rates published by the Ministry or by using general transfer pricing rules. Each company can opt which of these two approaches to take, however, selected approach needs to be applied on all intercompany loans. In that respect, it can be noted that, while interest rates published by the Ministry provide for a fixed rate for each category, analysis under general rules can provide an arm’s length range rather than a single value and can take into account specific conditions and comparability factors of the particular intercompany loan.
