Transfer pricing in Serbia: Facing a sobering reality

This paper attempts to systematize the basic pillars of Serbian policy in the area of corporate income taxation of related party transactions (transfer pricing). The author looks at the very first Serbian transfer pricing legislation introduced in 1991 and follows its development through to the pres...

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Main Author: Kostić Svetislav V.
Format: Article
Language:English
Published: University of Belgrade, Faculty of Law, Belgrade, Serbia 2017-01-01
Series:Anali Pravnog Fakulteta u Beogradu
Subjects:
Online Access:http://scindeks-clanci.ceon.rs/data/pdf/0003-2565/2017/0003-25651704075K.pdf
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author Kostić Svetislav V.
author_facet Kostić Svetislav V.
author_sort Kostić Svetislav V.
collection DOAJ
description This paper attempts to systematize the basic pillars of Serbian policy in the area of corporate income taxation of related party transactions (transfer pricing). The author looks at the very first Serbian transfer pricing legislation introduced in 1991 and follows its development through to the present. Principle focus is directed towards the policy drivers behind the 2012 and 2013 comprehensive reform of the Serbian transfer pricing provisions, which the author analyses with the added value of hindsight. Despite a generally positive view on what was achieved by the 2012 amendments to the Serbian transfer pricing legislation, the author offers a divergent view. A critical assessment is provided and the author stipulates the reasons which suggest that the respective amendments failed to meet desired goals in the area of transfer pricing set in 2012 and 2013. The author tries to deduce the lessons that should be taken into consideration in the future legislation reform initiatives and attempts to find alternative paths that should be taken in order to avoid repeating identical mistakes.
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publisher University of Belgrade, Faculty of Law, Belgrade, Serbia
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spelling doaj-art-81f7fc19d8034e43be1f33aa35af416f2025-08-20T01:55:44ZengUniversity of Belgrade, Faculty of Law, Belgrade, SerbiaAnali Pravnog Fakulteta u Beogradu0003-25652406-26932017-01-01654759010.5937/AnaliPFB1704075K0003-25651704075KTransfer pricing in Serbia: Facing a sobering realityKostić Svetislav V.0Faculty of Law, Belgrade%SR13-01.10This paper attempts to systematize the basic pillars of Serbian policy in the area of corporate income taxation of related party transactions (transfer pricing). The author looks at the very first Serbian transfer pricing legislation introduced in 1991 and follows its development through to the present. Principle focus is directed towards the policy drivers behind the 2012 and 2013 comprehensive reform of the Serbian transfer pricing provisions, which the author analyses with the added value of hindsight. Despite a generally positive view on what was achieved by the 2012 amendments to the Serbian transfer pricing legislation, the author offers a divergent view. A critical assessment is provided and the author stipulates the reasons which suggest that the respective amendments failed to meet desired goals in the area of transfer pricing set in 2012 and 2013. The author tries to deduce the lessons that should be taken into consideration in the future legislation reform initiatives and attempts to find alternative paths that should be taken in order to avoid repeating identical mistakes.http://scindeks-clanci.ceon.rs/data/pdf/0003-2565/2017/0003-25651704075K.pdftransfer pricingamendmentssafe harborOECD
spellingShingle Kostić Svetislav V.
Transfer pricing in Serbia: Facing a sobering reality
Anali Pravnog Fakulteta u Beogradu
transfer pricing
amendments
safe harbor
OECD
title Transfer pricing in Serbia: Facing a sobering reality
title_full Transfer pricing in Serbia: Facing a sobering reality
title_fullStr Transfer pricing in Serbia: Facing a sobering reality
title_full_unstemmed Transfer pricing in Serbia: Facing a sobering reality
title_short Transfer pricing in Serbia: Facing a sobering reality
title_sort transfer pricing in serbia facing a sobering reality
topic transfer pricing
amendments
safe harbor
OECD
url http://scindeks-clanci.ceon.rs/data/pdf/0003-2565/2017/0003-25651704075K.pdf
work_keys_str_mv AT kosticsvetislavv transferpricinginserbiafacingasoberingreality