Transactions between related parties both domestic and multinational corporations are increasingly becoming the focus of the Tax Administration. In this sense, companies are still struggling with the challenges in ensuring adequate supporting documentation on transfer pricing, tax assessment of risks arising from transactions with related parties, as well as adequate representation of their positions prior to the tax authorities – the explanation of its reasons, intercompany transactions and justification for using transfer prices.

Our services in the field of Transfer pricing include:

  1. Analysis of the group of related entities to which taxpayer belongs to
  2. Analysis of the industry
  3. Functional Analysis
  4. The choice of method for checking compliance of transfer prices with prices established on the principle of "Arm’s length"
  5. Conclusion – whether it is necessary to perform the correction of the tax base for transactions with related entities
  6. Attachments – overview of data that the taxpayer is used to determine the price based on the principle “Arm’s length”

Download the list of documents necessary for the preparation of studies on transfer pricing HERE

Who has the obligation to submit the report on transfer pricing, and who is considered a related party?

Law on Corporate Income Tax Law, in Article 59, described the four levels of integration. Related persons shall be:

  1. Legal entities between which there is a possibility of control or the possibility of significant impact on business decisions – the possession of at least 25% stake or shares, or votes in management bodies (Article 59, para. 3 and 4 of the Act)
  2. Legal entities with the same physical or legal persons involved in the management and control or capital (Article 59, paragraph 5 of the Act)
  3. The family owners of legal entities that are connected on the basis of possession of at least 25% stake or shares, or votes in management bodies (Article 59, paragraph 6 of the Act)
  4. Legal entities from jurisdictions with preferential tax system – the so-called. tax havens (Article 59, paragraph 7 of the Act).


Agencija INEKS-M Hajduk Veljkova 28/I 14000 Valjevo,
Milan Jeremic, owner:
Phone +381 14 247-471
247-470, 244-777
Mobile: +381 63 214 329
Fax: +381 14 247-471