Corporate - Significant developments

Last reviewed - 07 June 2022

Starting from the corporate income tax (CIT) assessment for 2019, tax depreciation of fixed assets (apart from real estate and fixed assets acquired before 31 December 2018) will be calculated by using the straight-line depreciation method.

Resident legal entities that are considered to be the ultimate parent of a multinational group are obligated to submit a country-by-country (CbC) report.

In December 2018, three new incentives were introduced:

  • Double deduction for research and development (R&D) costs:  R&D costs related to R&D performed in the Republic may be double deducted for CIT purposes (excluding extractive industry).
  • Royalty income relief:  80% of qualified royalty income generated by the copyright or similar rights holders (inscribed in relevant register in Serbia) can be excluded from the tax base. Qualifying income should be excluded upon decreasing this income for the amount of tax deductible R&D costs incurred in relation to development of such copyright/similar right.
  • Tax credit:  30% tax credit for the investments into newly established companies performing innovative activities (tax credit up to 846,000 euros [EUR]).

At the end of 2021, changes in the CIT Law introduced the possibility for taxpayers to exempt the capital gains that arose from contribution in kind of copyrights and patents to the capital of another resident legal entity under the conditions that:

  • resident legal entity does not alienate rights in the period of two years from the moment when the rights were acquired
  • in the same period, the resident legal entity does not transfer the acquired rights to another entity for a price lower than the price that would be determined by applying the arm's length principle

Value of the rights at the moment of the contribution shall be determined by an appraisal performed by an authorised appraiser.