Serbia: Business Environment

Company Tax

15%

Tax Rate For Foreign Companies

Residents are taxed on their worldwide income. Non-resident companies are only taxed on the part of their income generated through a permanent establishment in Serbia.
An entity is deemed to be resident of Serbia if it is established or has its place of effective management and control in Serbia.

Capital Gains Taxation

Capital gains obtained by resident companies are included in the annual income tax return and subject to tax at 15%, whereas those obtained by non-resident entities are taxed at 20% (unless a lower rate is provided under a tax treaty). Non-residents should appoint a fiscal representative in Serbia who should submit a tax return within 30 days from the realisation of capital gain.
Gains can be offset with capital losses occurring in the same period, and capital losses can be carried forward for five years.

Main Allowable Deductions and Tax Credits

Depreciation of tangible and intangible assets is tax-deductible at rates ranging from 2.5% to 30%. Goodwill is not deductible.
Start-up fees are generally deductible. Interest charges that exceed the thin capitalisation limits and transfer pricing thresholds are not deductible.
Bad debts are tax-deductible if they are at least 60 days overdue.
Donations to charities and humanitarian aid to national and local authorities in urgent cases are deductible up to 5% of income.
Fines are not deductible while taxes that do not depend on the profitability of the company are deductible.
Expenses directly related to qualifying R&D activities performed in Serbia are eligible for a double deduction. The Serbian intellectual property box regime offers an exclusion from the corporate income tax base of 80% of qualified income received by a taxpayer for the use of registered copyrights, patents, or related rights (does not include income derived from the disposal of the rights).
Investments in newly established companies that perform innovative activities give the right to a tax credit equivalent to 30% of the investments made (capped at RSD 100 million).
Entertainment expenses are deductible up to 0.5% of income. Finally, membership fees to chambers of commerce and associations (excluding political parties) are deductible up to 0.1% of income.
Tax losses can be carried forward for up to five years. The carryback of losses is not permitted.

Other Corporate Taxes

A property tax is payable not only by homeowners but also by long-term tenants (one year or more) and urban land users (ten acres or more). The maximum rate is 0.4%.
A transfer tax is levied on all types of transfers (property, vehicles, intellectual property, etc.) at a rate of 2.5%.
Although there are no stamp duties, the competent authorities and/or notary may charge fees when certifying documents relating to property transfers.
Social security contributions payable by the employer amount to 16.65% of the gross salary (11.5% for pension and disability insurance and 5.15% for health insurance), limited to five average monthly salaries.

Other Domestic Resources

Tax Administration

Consult Doing Business Website, to obtain a summary of the taxes and mandatory contributions.

Tax Rate

Allowable Deductions and Tax Credits

Personal allowances are available to the members of the taxpayer's family that are financially supported by the taxpayer.
Taxpayers have the right to a 40% deduction of their average annual salary, plus 15% of the average annual salary per dependent. In any case, the total deduction cannot exceed 50% of the taxable income.

Special Expatriate Tax Regime

Residents are taxable on their worldwide income, whereas non-residents are taxable on their Serbian-sourced income and worldwide income related to their work in/for the Republic of Serbia.
An individual is considered resident for income tax purposes if he/she has a residence or centre of business and/or vital interests in Serbia or stays in the country for at least 183 days in a 12-month period commencing or ending in the tax year concerned.