“Official Gazette” No. 95/2021 published modified The Rulebook on Transfer Prices and Application of the Arm´s Length Methods to Related Party Transaction Price Determination (hereinafter: the Rulebook on Transfer Pricing), which begins to apply from 01.10.2021.
The modified Rulebook on Transfer Pricing defines in more detail the content and manner of submitting the annual report on controlled transactions of the international group of related parties (CbC Report).
The obligation to submit the annual report has a resident taxpayer who is considered the ultimate parent legal entity of an international group of related parties whose total consolidated revenue in the previous year amounts to at least EUR 750 million.
The annual report is submitted on the CbC form in paper form, no later than 12 months from the end of the tax period.
The amendments do not introduce a separate notification about submitter of the annual report (Notification requirement), but the taxpayer is obliged to provide the following information in the annual transfer pricing documentation:
- Is the taxpayer a member of an international group of related parties and is it considered the ultimate parent entity in terms of Article 61v of the Corporate Income Tax Law, which regulates the submission of the annual report;
- If the taxpayer is not considered the ultimate parent entity, information on the identity and residency of the ultimate parent entity.
The TPA Serbia expert team is at your disposal for all questions.