🇷🇸 Serbia
Europe & Central Asia · ISORA participant ·
Serbia has implemented statutory interest limitation rules and requires statutory country-by-country reporting. The country does not utilize automated bulk data matching or controlled foreign company rules. In 2022, tax revenue accounted for 23.9% of GDP based on central government figures.Auto-generated summary of the verified data below; every fact traces to a source on this page.
23.9%
tax-to-GDP, central govt only (2022, World Bank)
5/11
enforcement powers assessed
Headline statutory rates
As stated in PwC Worldwide Tax Summaries’ territory overview (fetched 2026-08-20) — the wording is PwC’s; source.
| Tax | Headline rate as stated |
|---|---|
| Headline PIT rate | 10 - 20 (Dependent on the income type) |
| Headline CIT rate | 15 |
| Standard VAT rate | 20 |
| Headline individual capital gains tax rate | 15 |
| Headline corporate capital gains tax rate | 15 |
| WHT rates (%) (Dividends/Interest/Royalties) | Resident: NA; Non-resident: 20 / 20 / 20; Non-resident in tax haven: 20 / 25 / 25 |
| Headline net wealth/worth tax rate | NA |
| Headline inheritance tax rate | 0 - 2.5 (depends on the line of succession) |
| Headline gift tax rate | 2.5 NA stands for Not Applicable (i.e. the territory does not have the indicated tax or requirement) NP stands for Not Provided (i.e. the information is not currently provided in this chart) |
Enforcement powers
Automated bulk data matching No — power absent
Self-reported to ISORA (International Survey on Revenue Administration), FY2022.
“ISORA indicator "Administration undertakes fully automated compliance checks based on data matching/analysis" — value: No”
Source: IMF ISORA — International Survey on Revenue AdministrationOECD / IMF survey data · derived from the administration’s own survey answer
Controlled foreign company (CFC) rules No — power absent
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there a controlled foreign company rule in place? · Not applicable" — No”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Interest limitation rules Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there an interest limitation rule in place? · Regime 1" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Country-by-country reporting Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (0).
“OECD Corporate Tax Statistics: "Is there a country-by-country reporting law in place?" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Public naming of non-compliant taxpayers No — power absent
Self-reported to ISORA (International Survey on Revenue Administration), FY2022.
“ISORA indicator "Administration is empowered to make public details of some / all taxpayers subject to administrative penalties imposed for non-disclosure" — value: No”
Source: IMF ISORA — International Survey on Revenue AdministrationOECD / IMF survey data · derived from the administration’s own survey answer
Anti-avoidance regime detail (OECD Corporate Tax Statistics)
OECD-curated descriptions of this jurisdiction’s CFC, interest-limitation, CbCR and IP-regime rules.
CFC rules — 2 data points
| Is there a controlled foreign company rule in place? · Regime 1 | No |
| Is there a controlled foreign company rule in place? · Not applicable | No |
Interest limitation — 21 data points
| Do any loss carry-back or carry-forward provisions apply? · Regime 1 | No |
| Is a de minimis threshold present? · Regime 1 | / |
| Any other exclusions? · Regime 1 | No |
| Exclusions based on payer characteristics? · Regime 1 | No |
| Exclusions based on payment characteristics? · Regime 1 | No |
| Exclusions based on recipient characteristics? · Regime 1 | No |
| Financial accounting measure applied to rule · Regime 1 | debt-to-equity |
| Is there a group ratio rule or similar type of rule in place? · Regime 1 | No |
| Is there an interest limitation rule in place? · Regime 1 | Yes |
| Is there an interest limitation rule in place? · Rule 1 | Yes |
| Can interest be recharacterised as a dividend? · Regime 1 | No |
| Is the rule is applicable to net or gross interest expensing? · Regime 1 | gross |
| Other mechanisms for providing taxpayers with relief where the MNE group has high levels of third party interest expense. · Regime 1 | The total accounted interest, other than interest charged for untimely payment of taxes, contributions and other public charges, shall be recognized as expenditure in the tax statement. In the case of loans from related parties, the thin capitalization rule applies |
| Is the rule applicable to related party debt? · Regime 1 | Yes |
| Description of interest limitation rule · Regime 1 | In debt to the creditor a related company, the taxpayer, except for the bank and the company which carries out financial leasing activities in accordance with the regulations governing financial leasing (hereinafter referred to as the provider of financial leasing), are recognized as liabilities in the tax balance the amount of interest and related expenses on the loan, or a loan up to the amount … |
| Type of interest limitation rule · Regime 1 | Thin cap |
| Type of interest limitation rule · Rule 1 | Thin cap |
| Financial ratio referenced · Regime 1 | 10:1 for banks and financial lessors, 4:1 for other taxpayers |
| Is the rule is applicable to third party debt? · Regime 1 | No |
| Are there targeted rules to address specific risks not addressed by the general rule? · Regime 1 | No |
| Are there targeted rules to address specific risks not addressed by the general rule? · Rule 1 | No |
Country-by-country reporting — 4 data points
| Is there a country-by-country reporting law in place? | Yes |
| Deadline by which filings must be submitted | 12 months |
| Reports are required for MNEs with annual revenues above | EUR 750 million or near equivalent in domestic currency |
| Headquarter jurisidiction filing required from | 01-Jan-20 |
Effective corporate tax rates
| Measure | Year | Rate |
|---|---|---|
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 12.3% |
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 3.5% |
| Capital allowances · Percentage of initial investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 8.9% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 13.9% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 7.4% |
| Capital allowances · Percentage of initial investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 11.8% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 16.2% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 16.0% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 17.6% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 13.9% |
| Effective average tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 16.3% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 14.2% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 14.4% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 14.7% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 14.1% |
| Effective average tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 14.8% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 27.6% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 26.0% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 40.0% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 7.9% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 28.3% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 11.2% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 13.2% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 15.3% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 10.6% |
| Effective marginal tax rate · Percentage of taxable income · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 15.9% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Acquired software · Not applicable | 2025 | 3.5% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Composite · Not applicable | 2025 | 3.5% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Inventories · Not applicable | 2025 | 3.9% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Buildings · Not applicable | 2025 | 3.0% |
| Cost of capital · Percentage of investment · Baseline · Country-specific interest and inflation rates · Tangibles · Not applicable | 2025 | 3.6% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Acquired software · Not applicable | 2025 | 3.3% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Composite · Not applicable | 2025 | 3.4% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Inventories · Not applicable | 2025 | 3.5% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Buildings · Not applicable | 2025 | 3.3% |
| Cost of capital · Percentage of investment · Baseline · Fixed interest and inflation rates · Tangibles · Not applicable | 2025 | 3.5% |
OECD Corporate Tax Statistics, baseline scenario.
Administration self-reported metrics (ISORA)
Reported by the administration itself to the IMF/OECD/CIAT/IOTA International Survey on Revenue Administration. 1 = yes, 0 = no for policy questions.
| Indicator | Year | Value |
|---|---|---|
| Percentage of tax returns - Electronic, not prefilled - CIT | 2024 | 100 |
| Percentage of tax returns - Electronic, not prefilled - PIT | 2024 | 100 |
| Percentage of tax returns - Electronic, not prefilled - VAT | 2024 | 100 |
| Population per FTE | 2024 | 1867.444286929402 |
| Labor force per FTE | 2024 | 915.550893110292 |
| Corporate taxpayers per FTE in LTO/P | 2024 | 7.714285714285714 |
| Active taxpayers on PIT register as percentage of Population | 2024 | 41.21815671992124 |
| Active taxpayers on PIT register as percentage of Labor Force | 2024 | 84.0724550252884 |
| Closing stock of collectable arrears as percentage of closing stock of arrears | 2024 | 30.77301963493541 |
| CIT arrears as percentage of CIT collected | 2024 | 3.566975360756452 |
| PIT arrears as percentage of PIT collected | 2024 | 1.195913878347717 |
| PAYE arrears as percentage of PIT collected | 2024 | 2.449047331239411 |
| VAT arrears as percentage of VAT collected | 2024 | 1.908444555319945 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - PIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - PIT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - PIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - VAT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - VAT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - VAT | 2021 | 0 |
| Additional assessments raised through all audits and verification actions as percentage of tax collections | 2024 | 1.827486817838699 |
| Audit hit rate | 2024 | 39.83574202584835 |
| Percentage of tax returns - Electronic, not prefilled - PAYE | 2024 | 98.1232225683957 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, not modified by taxpayer - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - PAYE | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - PAYE | 2024 | 1.876777431604302 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - VAT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - VAT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - PAYE | 2024 | 1.876777431604302 |
| Percentage of tax returns - Electronic, prefilled Total - VAT | 2024 | 0 |
| Availability of specific powers in legislation / regulation to assist in collecting tax arrears | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Common administrative penalty framework for non-disclosure across the major tax types | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Penalties imposed generally take account of taxpayers' culpability (i.e. degree of blame) | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Administration is empowered to remit / reduce penalties in appropriate circumstances | 2022 | 0 |
| Administrative sanctions for taxpayer non-disclosure - Administration is empowered to make public details of some / all taxpayers subject to administrative penalties imposed for non-disclosure | 2022 | 0 |
| On-time filing rate % - CIT | 2024 | 87.09661570711496 |
| On-time filing rate % - PIT | 2024 | 94.18570919428765 |
| On-time filing rate % - VAT | 2024 | 94.80619833671668 |
| On-time filing rate % - PAYE | 2024 | 94.18719842604024 |
| Administration pre-fills PIT returns or assessments | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Income information: Other income | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Income information: Wages and salaries | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Taxpayer personal information | 2024 | 1 |
| Categories of third party information used to pre-fill PIT returns or assessments-Expense information: Other expenses | 2023 | 1 |
| Administration conducts random audits | 2022 | 1 |
| E-filing mandatory - CIT | 2022 | 1 |
| E-filing mandatory - PIT | 2022 | 1 |
| E-filing mandatory - Employer Withholdings | 2022 | 1 |
| E-filing mandatory - VAT | 2022 | 1 |
| E-payment mandatory - CIT | 2022 | 0 |
| E-payment mandatory - PIT | 2022 | 0 |
| E-payment mandatory - Employer Withholdings | 2022 | 0 |
| E-payment mandatory - VAT | 2022 | 0 |
| Employers withholding taxes on behalf of salaried employees | 2024 | 1 |
| Percentage of payments received electronically-By number of payments | 2024 | — |
| Percentage of payments received electronically-By value of payments | 2024 | — |
| Cooperative compliance approach exists for -Large taxpayers | 2024 | 1 |
| Cooperative compliance approach exists for -HNWI taxpayers | 2024 | 0 |
| Cooperative compliance approach exists for -Other taxpayers | 2024 | 1 |
| Most employees that have tax deducted through direct withholding required to file a return | 2024 | 0 |
| Administration receives data from devices that register transactions | 2024 | 1 |
| Administration uses electronic compliance checks as part of returns filing process | 2024 | 1 |
| Administration has specialized audit staff for international tax issues | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Customs data | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data from stock exchanges | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data from the Social Security Agency | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data from online (internet-based) vendors | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data from Utilities | 2022 | 0 |
| Administration checks the quality of data reported by third parties on a systematic basis | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data on property ownership and sales | 2022 | 1 |
| Administration undertakes fully automated compliance checks based on data matching/analysis | 2022 | 0 |
| Administration measures the effectiveness of any compliance interventions undertaken | 2022 | 1 |
| Administration has standards for auditor productivity | 2022 | 1 |