Serbia: Rulebook on arm’s length interest rates for 2025
Interest rates for all non-finance entities and a single interest rate for banks and finance leasing companies
The Ministry of Finance adopted the rulebook on arm’s length interest rates for 2025. The rulebook was published in the Official Gazette of Serbia No. 17/2025 dated February 28, 2025, and is effective March 8, 2025.
Background
According to the provisions of article 61 of the corporate income tax law, in determining arm’s length interest expense/revenue, taxpayers can:
- Use interest rates as prescribed by the rulebook
- Apply general OECD-based methods for assessment of arm’s length interest as prescribed by the corporate income tax law
Taxpayers may opt only for one of the above options. The selected option needs to be consistently applied to all intercompany loans.
Rulebook
The rulebook prescribes separate interest rates for long-term and for short-term borrowings for all non-finance entities and a single interest rate for banks and finance leasing companies (except for RSD denominated loans when interest rate is prescribed separately for short term and long-term loans).
