Corporate - Group taxationLast reviewed - 17 January 2023
There are no group taxation rules applicable in Kosovo.
Transfer pricing regime
In July 2017, Kosovo introduced transfer pricing rules, which are applicable from fiscal year 2017.
These rules apply to Kosovo CIT payers that have entered into controlled transactions with related parties established in foreign tax jurisdictions.
The transfer pricing rules generally follow the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, whereas documentation requirements are as per the EU Code of Conduct on Transfer Pricing Documentation for Associated Enterprises in the European Union (2006/C 176/01).
Recognised transfer pricing methods include the comparable uncontrolled price (CUP) method, resale price (RP) method, cost plus (C+) method, transactional net margin (TNM) method, and profit split (PS) method. A simplified approach is applicable for low value-adding intra-group services.
Taxpayers with controlled transactions exceeding EUR 300,000 in a calendar year are required to:
- prepare transfer pricing documentation as per the EU Code of Conduct on Transfer Pricing Documentation for Associated Enterprises in the European Union (2006/C 176/01), and
- submit an Annual Controlled Transactions Notice by 31 March of the following year, along with statutory financial statements and CIT declaration.
Taxpayers with controlled transactions of EUR 300,000 or less in a calendar year are required to prepare documentation, but are not required to submit an Annual Controlled Transactions Notice.
Thin capitalisation rules
There are no thin capitalisation rules applicable in Kosovo.
Controlled foreign companies (CFCs)
There is no CFC regime in Kosovo.