Bosnia and Herzegovina transfer pricing (2026)

There is no state-level transfer pricing law in Bosnia and Herzegovina. The rules sit inside the profit tax law of each entity and of Brčko District:

• FBiH: Zakon o porezu na dobit ("Službene novine FBiH" 15/16 and 15/20), arts. 44 to 46, 49 and 58, with the Pravilnik o transfernim cijenama (67/16, amended by 92/24 from 1 January 2025). Authority: Porezna uprava FBiH (pufbih.ba).
• RS: Zakon o porezu na dobit ("Službeni glasnik RS" 94/15, 1/17, 58/19, 48/24 and 114/25), arts. 31 to 35 and 58, with the Pravilnik o transfernim cijenama i metodama za njihovo utvrđivanje (47/16). The 114/25 changes apply from 1 January 2026. Authority: Poreska uprava RS (poreskaupravars.org).
• BD: Zakon o porezu na dobit ("Službeni glasnik BD" 17/22 consolidated, and 38/22), arts. 2 and 8 to 9.

Apply the law of the place where the company (or its branch) is taxed on profit. A company seated in the FBiH with a branch in the RS deals with both. Amounts are in convertible marks (KM, BAM). The profit tax computation itself is in ba-corporate-income-tax.

Who this applies to

• Any profit taxpayer that deals with a related party, at home or abroad. The rules cover sales, purchases, transfers of assets and rights, and services where at least one party is an FBiH profit taxpayer (FBiH Rulebook art. 2(1)). In the RS, controlled transactions include goods, services, intangibles, financing (leasing fees, interest, guarantees), capital transactions such as share sales and any other transaction that can affect the tax base (RS Rulebook art. 3).
• Branches and permanent establishments. In the FBiH, the profit of a branch must match what an independent company doing the same work would earn (FBiH law art. 7(8)), and the rulebook applies by analogy between a branch and its head office (FBiH Rulebook art. 2(2)). From 2026 the RS law says the same for a non-resident's permanent establishment, weighing functions, assets and risks (RS law art. 40(7), added by 114/25).
• Related party, FBiH (law art. 44(3)). Any two persons where one acts, or is likely to act, on the other's instructions, or both act on a third person's instructions. In particular: close family; a company and any individual owning directly or indirectly 25% or more of its value, shares or votes; and two or more companies where one person owns 25% or more in each. The rulebook adds companies that control or are controlled by the taxpayer, and anyone who knowingly enters a deal to shift profit (FBiH Rulebook art. 6).
• Related party, RS (law art. 31). A person is related to another when it takes part directly or indirectly in its management, control or capital, or the same person does so in both. That means at least 25% of shares or interests, or actual control: 25% or more of votes, control over the board, a right to 25% or more of profit, family ties, or control in another way.
• Related party, BD (law art. 2(j)). A lower test: an individual or company owning, directly or indirectly, at least 10% of the shares or capital of a company. Family holdings (spouse, children, adopted children, parents, siblings, grandparents, grandchildren) count as the individual's own.

Rates, bands and thresholds

Item	Rate or amount	Year	Source
Related party, FBiH	25% or more of value, shares or votes, or acting on another's instructions	2026	FBiH law art. 44(3): https://ik.imagekit.io/9qcwbg8wl/15-16_i_15-20-zakon-o-porezu-na-dobit-precisceni_07YP9wNd9.pdf
Related party, RS	25% of shares or interests, 25% of votes or profit share, board control, family, or actual control	2026	RS law art. 31(3), (4): https://www.poreskaupravars.org/dokumenti/zakoni/Zakon%20o%20porezu%20na%20dobit%20od%2001_01_2016.pdf
Related party, BD	10% of shares or capital	2026	BD law art. 2(j): https://skupstinabd.ba/3-zakon/ba/Zakon%20o%20porezu%20na%20dobit/05B17-22%20Zakon%20o%20porezu%20na%20dobit%20-%20prec--is--eni%20tekst.pdf
FBiH annual report on controlled transactions (Form TP-902)	Required when controlled transactions exceed KM 500,000 in the year; due 31 March of the next year	2026	FBiH law art. 49(3); FBiH Rulebook art. 92(1), (2): https://www.pufbih.ba/v1/public/upload/zakoni/ae0c4-pravilnik-o-transfernim-cijenama-preciscen-tekst.pdf
FBiH documentation on request	Within 45 days of the request	2026	FBiH law art. 46(2); FBiH Rulebook art. 94
FBiH master file and country-by-country report (Form CBC-901)	Group consolidated revenue of EUR 750 million or more (KM at the Central Bank rate); CBC-901 due 12 months after the group's year end	2026	FBiH Rulebook arts. 70(2), 91(3), (4) as amended by 92/24: https://www.pufbih.ba/v1/public/upload/zakoni/80e33-pravilnik-o-izmjenama-pravilnika-o-transfernim-cijenama-92-24.pdf
FBiH support services mark-up	5% on cost accepted as arm's length, if the conditions are met	2026	FBiH Rulebook art. 54(2)
FBiH cost pooling: "not the main activity" presumption	Service costs up to 15% of the provider's total costs	2026	FBiH Rulebook art. 56(3)(c)
FBiH comparables	Interquartile range (first to third quartile); weighted average of 3 to 5 years	2026	FBiH Rulebook art. 25(3), (4)
FBiH industry analysis waived	Activity under 10% of total revenue	2026	FBiH Rulebook art. 85(2)
FBiH domestic relief claim (Form TP-900)	With the profit tax return, by 31 March; a late form counts as not filed	2026	FBiH Rulebook art. 95(3)
RS documentation threshold	Controlled transactions (including credits and loans) over KM 50,000 in the year	2026	RS law art. 34(1) as amended by 114/25 art. 10: https://poreskaupravars.org/wp-content/uploads/2025/12/Dobit-1.pdf
RS documentation filing	Electronically within 30 days of a request, and in any case within 9 months after the year end without a request	2026	RS law art. 34(2) as amended by 114/25 art. 10
RS annual return of controlled transactions	Controlled transactions (including loans) over KM 700,000 in the year, no netting of income and expenses; filed with the profit tax return	2026	RS Rulebook art. 13: https://www.poreskaupravars.org/dokumenti/pravilnici/Pravilnik%20o%20transfernim%20cijenama%20i%20metodama%20za%20njihovo%20utvrdjivanje.pdf
RS country-by-country data in the documentation	Group revenue over EUR 750,000,000	2026	RS Rulebook art. 12(2)(4)
RS adjustment point	Median of the arm's length range, unless a party proves another point fits	2026	RS Rulebook art. 11(3), (4)
Fines, FBiH	Company KM 3,000 to 100,000; responsible person KM 2,500 to 10,000; repeat offence +50%	2026	FBiH law art. 58(2) to (4)
Fines, RS	Company KM 20,000 to 60,000; responsible person KM 5,000 to 15,000	2026	RS law art. 58 (94/15; point 2 amended by 114/25 art. 17)
Late-payment interest	FBiH 0.04% a day; RS 0.03% a day; BD 0.03% a day, capped at the principal	2026	FBiH: https://pufbih.ba/v1/public/upload/zakoni/1%20Zakon%20o%20visini%20stope%20zatezne%20kamate%20na%20javne%20prihode%20-%20PRECISCEN%20TEKST.pdf art. 2; RS ZPP art. 60(1): https://poreskaupravars.org/wp-content/uploads/2020/11/Zakon-o-poreskom-postupku.pdf; BD Zakon o Poreznoj upravi art. 68

The taxable base

The arm's length rule.

• FBiH: a taxpayer in a related-party transaction must set its taxable profit at arm's length, meaning on the terms independent parties would agree in comparable transactions and circumstances (law art. 44(1), (2)). If it does not, taxable profit is raised by increasing income or reducing deductible expenses (art. 44(4)). Transactions are comparable when no material differences exist, or when reasonably accurate adjustments remove them (art. 45(1)).
• RS: the same rule (law art. 32(1) to (3)). If the terms are not at arm's length, the Tax Administration raises the base by increasing income or reducing deductible expenses (art. 32(4)). From 2026, anything the law and rulebook do not cover is read using the Ministry's published translation of the OECD Transfer Pricing Guidelines, where it does not conflict with them (art. 35(2), added by 114/25).
• BD: the transfer price is the price in transactions in assets or liabilities between related parties. If it does not match the market price, the Tax Administration raises or lowers income or expenses (law art. 9). The market price is what an unrelated buyer would pay an unrelated seller at the same time and place, for the same or similar goods or services, under free competition (art. 2(e)). Two items are never deductible: expenses to a related party above the market price, and a loss on selling or transferring any asset between related parties (art. 8(3)(f), (g)).

Methods.

• FBiH (law art. 45(2), (3)): use the most appropriate method. Choose first among the comparable uncontrolled price, cost plus and resale price methods. Only if none of them can be applied, use profit split, the transactional net margin method (TNMM) or any other method that gives an arm's length result.
• RS (law art. 33; Rulebook arts. 7, 8): comparable uncontrolled price, cost plus, resale price, TNMM or profit split. Another method is allowed only if the taxpayer proves none of the five can be applied. Methods can be combined. The choice weighs the strengths of the method, how well it fits the functions of each party, the data available and the degree of comparability. If the taxpayer chose and applied a method properly, the Tax Administration must audit using that method (Rulebook art. 8(3)). A foreign tested party is allowed if the method is the most suitable and the taxpayer gives enough information about it (Rulebook art. 9(3)).
• BD: the law names no methods. It leaves the way to set market value to a rulebook (art. 9(3)), which was not found on an official site (see Sources).

The range.

• FBiH: TNMM comparables are split into quartiles. Results between the first and third quartile form the arm's length range, using a weighted average of three to five years ending with the latest year for which data exist (Rulebook art. 25). Local comparables are used where possible; if there are not enough reliable ones, the search can widen to the region and beyond (Rulebook art. 42(4)). The FBiH rulebook does not fix the point of adjustment.
• RS: a result inside the range is arm's length. A result outside the range is moved to the median, unless the Tax Administration or the taxpayer proves the circumstances justify another point in the range; the party asking for another point carries the burden (Rulebook art. 11(2) to (4)). With an even number of results, the median is the average of the two middle results (art. 11(5)).

Services and financing (FBiH Rulebook).

• Support services (accounting and audit, receivables and payables management, HR, IT support, training and similar, art. 55) may be charged at cost plus 5%. Two conditions apply: the services are in the art. 55 list, and the provider does not offer them to independent parties (art. 54(2)).
• Cost pooling between group members is allowed without a mark-up if each share is stated in money, the services are not offered to outsiders, the services are listed in art. 55, and the arrangement is documented before the services start. Providing the services must not be the provider's main activity; that is presumed when the service costs are no more than 15% of its total costs (art. 56(3)).
• Intra-group loans and guarantees must carry an arm's length rate, and the comparable uncontrolled price method is the most reliable for interest (arts. 65(3), 66(2)).

Interest limits and other add-backs. These sit in the profit tax law, not the transfer pricing rules: FBiH 4:1 related-party debt to equity (law art. 18); RS 30% net interest cap (law art. 14a); FBiH non-deductibility of default interest, penalties and contract fines between related parties (law art. 9(1)(l)). See ba-corporate-income-tax.

Deadlines and filing

What	FBiH	RS	BD
Documentation ready	At the time the profit tax return is filed (law art. 46(1); Rulebook art. 83(1))	At the time the profit tax return is filed, for controlled transactions over KM 50,000 (law art. 34(1))	No documentation duty in the law
Given to the tax office	Within 45 days of a request (law art. 46(2); Rulebook art. 94)	Electronically within 30 days of a request, and at the latest 9 months after the year end without a request: 30 September 2027 for 2026 (law art. 34(2))	No rule in the law
Annual return of controlled transactions	Form TP-902 when controlled transactions exceed KM 500,000, by 31 March (law art. 49(3); Rulebook art. 92)	When controlled transactions exceed KM 700,000, filed with the profit tax return by 31 March (Rulebook art. 13; law art. 38)	None
Country-by-country	Form CBC-901 filed by an FBiH ultimate parent with group revenue of EUR 750 million or more, within 12 months of the group's year end (Rulebook art. 91)	CbC data form part of the documentation when group revenue exceeds EUR 750,000,000 (Rulebook art. 12(2)(4))	None
Domestic double tax relief	Form TP-900 with the return by 31 March (Rulebook art. 95)	None	None

Content of the documentation.

• FBiH: the transfer pricing report must cover at least the group structure and business, an industry analysis, a functional analysis, the choice of method, and a conclusion (Rulebook art. 83(1)). Groups at the EUR 750 million threshold also prepare a master file; everyone else prepares the local file (art. 70). A short report (group structure, method and conclusion only) is enough for: loans between related parties; transactions with an FBiH related party where TP-900 is used; loans with related parties in BiH; support services charged at cost plus 5%; and a single one-off sale or purchase of an asset other than goods (art. 83(2), (3)). The report is in an official BiH language; the master file may be in English (art. 90). Records are kept as long as the return itself (art. 89).
• RS: ten items, from a business overview and group structure through the functional and comparability analysis, choice of method, any advance pricing agreements abroad and a conclusion (Rulebook art. 12(2)). The documentation is in an official language of the RS, on paper or electronically (art. 12(4), (5)), though from 2026 the law requires electronic filing (law art. 34(2)).

Self-correction. If the analysis shows the prices were not at arm's length, the FBiH report states the method and the amount of the correction in the tax balance (FBiH Rulebook art. 88(3)). Correct it in the return, not after an audit. In the FBiH tax balance (Form PB-800-A or PB-800-B), unreported income goes on line 65 and excess expenses on line 66; the amount relieved through Form TP-900 goes on line 67; taxable profit after transfer pricing is line 63 + 65 + 66 − 67 (Pravilnik o primjeni Zakona o porezu na dobit art. 107).

Penalties and interest

FBiH.

• Fine of KM 3,000 to 100,000 for the company, plus KM 2,500 to 10,000 for the responsible person, for: not filing the overview of controlled transactions; not showing related-party transactions at arm's length; not holding transfer pricing documentation at filing; not giving it within the deadline after a request (law art. 58(2)(e), (g), (j), (k), (3)). Repeat offences add 50% (art. 58(4)).
• Late-payment interest of 0.04% a day on tax that is paid late, including tax from an adjustment (Zakon o visini stope zatezne kamate art. 2).

RS.

• Fine of KM 20,000 to 60,000 for the company, plus KM 5,000 to 15,000 for the responsible person, for: missing documentation; not giving it within 30 days of a request or, from 2026, within 9 months after the year end; not filing the annual return of controlled transactions (law art. 58(1)(1) to (3), (2); point 2 amended by 114/25 art. 17).
• Interest of 0.03% a day from the day after the due date (Zakon o poreskom postupku art. 60(1)).

BD.

• The profit tax law has no transfer pricing fine. An adjustment is taxed at 10% with interest of 0.03% a day, capped at the principal (Zakon o Poreznoj upravi art. 68).

Cross-border points

• Foreign related parties. The rules apply in the same way to foreign and domestic related parties. The FBiH TP-900 relief and the short-report options for loans cover only parties inside the FBiH or inside BiH (FBiH Rulebook arts. 83(3)(a), (b), 95(2)).
• Double tax abroad. Where a resident faces double tax because another country adjusted the price, it uses the mutual agreement procedure in the treaty (FBiH Rulebook art. 96). BiH treaties are listed in ba-cross-border.
• Inside BiH. A company in one entity dealing with a related company in the other entity or in BD is in a controlled transaction under both laws. The FBiH TP-900 relief does not reach an RS or BD counterparty (FBiH Rulebook art. 95(2)(a)).
• Withholding tax on related-party payments. Interest, royalties, management fees and services to a foreign related party can carry withholding tax (FBiH law art. 38; RS law arts. 44, 45; BD law arts. 29, 30). See ba-cross-border.
• Branches. Profit of a branch or PE is measured as if it were an independent company (FBiH law art. 7(8); RS law art. 40(7)). In the RS, interest on loans from head office and royalties paid to head office are not deductible for the PE (RS law art. 40(3), (4)).

Worked examples

Example 1: RS distributor below the range (2026)

A Banja Luka company buys all its goods from its Austrian parent and resells them in BiH. In 2026 its sales are KM 2,000,000 and its operating profit is KM 20,000, a net margin of 1%. Purchases from the parent are KM 1,500,000. A benchmark of comparable distributors gives a first quartile of 2.5%, a median of 4% and a third quartile of 6%.

Purchases are over KM 50,000, so documentation must exist at filing and be filed electronically by 30 September 2027 (law art. 34). They are also over KM 700,000, so the annual return of controlled transactions goes in with the profit tax return by 31 March 2027 (Rulebook art. 13). The 1% margin is below the range. The Tax Administration moves it to the median, 4% (Rulebook art. 11(3)). Arm's length operating profit is 2,000,000 x 4% = KM 80,000. The adjustment is KM 60,000 and the extra tax at 10% is KM 6,000. If that tax is paid 200 days late, interest at 0.03% a day is KM 360 (ZPP art. 60).

name: RS distributor adjusted to the median of the range (2026)
inputs:
  sales: 2000000
  operating_profit: 20000
  q1_margin_pct: 2.5
  median_margin_pct: 4
  purchases_from_parent: 1500000
  days_late: 200
steps:
  - tested_margin_pct: operating_profit / sales * 100
  - gap_to_q1: max(0, sales * q1_margin_pct / 100 - operating_profit)
  - over_doc_threshold: purchases_from_parent - 50000
  - over_return_threshold: purchases_from_parent - 700000
  - arm_length_profit: sales * median_margin_pct / 100
  - adjustment: arm_length_profit - operating_profit
  - extra_tax: adjustment * 0.10
  - interest: extra_tax * 0.0003 * days_late
expected:
  tested_margin_pct: 1
  gap_to_q1: 30000
  over_doc_threshold: 1450000
  over_return_threshold: 800000
  arm_length_profit: 80000
  adjustment: 60000
  extra_tax: 6000
  interest: 360

Example 2: FBiH support services charged at cost, and the TP-902 threshold (2026)

A Mostar company keeps the books and runs payroll for its sister company in Sarajevo, also an FBiH resident. It does not offer these services to outsiders. In 2026 the work cost KM 400,000 and it charged the sister exactly KM 400,000. It also bought goods worth KM 300,000 from its Croatian parent at a price its benchmark supports. Neither FBiH company uses an investment or employment incentive or has a tax loss.

Accounting and payroll are support services (Rulebook art. 55). Instead of a benchmark study, the company applies the 5% mark-up (art. 54(2)). The arm's length charge is 400,000 x 1.05 = KM 420,000. It enters the KM 20,000 difference on line 65 of its 2026 tax balance (Form PB-800-A), which on its own costs KM 2,000 in tax. A short report is enough for this service (art. 83(3)(c)).

Both companies are FBiH residents and neither uses an incentive or has a tax loss (art. 95(2)(b), (c)). If both also show this transaction at transfer prices in their tax base (art. 95(2)(a)), the company files Form TP-900 with its return by 31 March 2027 and enters the same KM 20,000 on line 67, which takes it back out: taxable profit after transfer pricing is line 63 + 65 + 66 − 67 (Pravilnik o primjeni Zakona o porezu na dobit art. 107). The extra tax is then nil instead of KM 2,000. Its controlled transactions total KM 700,000, which is over KM 500,000, so Form TP-902 is also due by 31 March 2027 (law art. 49(3); Rulebook art. 92).

name: FBiH support services at cost plus 5% and TP-902 test (2026)
inputs:
  service_cost: 400000
  charged: 400000
  purchases_from_parent: 300000
steps:
  - arm_length_charge: service_cost * 1.05
  - adjustment: arm_length_charge - charged
  - extra_tax: adjustment * 0.10
  - line_67_relief: adjustment
  - tax_after_tp900: (adjustment - line_67_relief) * 0.10
  - controlled_total: charged + purchases_from_parent
  - over_tp902_threshold: controlled_total - 500000
expected:
  arm_length_charge: 420000
  adjustment: 20000
  extra_tax: 2000
  line_67_relief: 20000
  tax_after_tp900: 0
  controlled_total: 700000
  over_tp902_threshold: 200000

Ask the client first

1. Where is each company and branch registered: FBiH, RS or BD? That decides the law, the thresholds and the deadlines.
2. Who owns whom, and by what percentage, including family holdings? BD treats 10% as related; FBiH and RS use 25% or actual control.
3. What were the total controlled transactions in the year, including loans, split by counterparty? This decides TP-902 (FBiH, over KM 500,000), RS documentation (over KM 50,000) and the RS annual return (over KM 700,000).
4. Does the group's consolidated revenue reach EUR 750 million? That brings in the master file and country-by-country reporting.
5. Is documentation or a benchmark already prepared for another country? FBiH accepts relevant group documentation as part of the local file (Rulebook art. 76(2)).
6. Any intra-group services, loans or guarantees, and on what terms?

Sources

Source	URL	Read on
FBiH Zakon o porezu na dobit, 15/16 and 15/20, unofficial consolidated text: arts. 7(8), 9(1)(l), 18, 38, 44 to 46, 49, 58	https://ik.imagekit.io/9qcwbg8wl/15-16_i_15-20-zakon-o-porezu-na-dobit-precisceni_07YP9wNd9.pdf	2026-10-30
FBiH Pravilnik o transfernim cijenama, 67/16 and 92/24, unofficial consolidated text: arts. 1 to 3, 6, 25, 42, 54 to 56, 65, 66, 68 to 70, 76, 83, 85, 88 to 96	https://www.pufbih.ba/v1/public/upload/zakoni/ae0c4-pravilnik-o-transfernim-cijenama-preciscen-tekst.pdf	2026-10-30
FBiH Pravilnik o izmjenama Pravilnika o transfernim cijenama, 92/24 (EUR 750 million thresholds, CBC-901 deadline; applies from 1 January 2025)	https://www.pufbih.ba/v1/public/upload/zakoni/80e33-pravilnik-o-izmjenama-pravilnika-o-transfernim-cijenama-92-24.pdf	2026-10-30
FBiH Pravilnik o primjeni Zakona o porezu na dobit, consolidated to 39/26: art. 107 (tax balance lines 63 to 68)	https://pufbih.ba/v1/public/upload/zakoni/03062026%20Pravilnik%20o%20primjeni%20Zakona%20o%20porezu%20na%20dobit%2039-26.pdf	2026-10-30
Porezna uprava FBiH, list of regulations in force	https://pufbih.ba/api/regulations	2026-10-30
FBiH Zakon o visini stope zatezne kamate na javne prihode, consolidated: art. 2	https://pufbih.ba/v1/public/upload/zakoni/1%20Zakon%20o%20visini%20stope%20zatezne%20kamate%20na%20javne%20prihode%20-%20PRECISCEN%20TEKST.pdf	2026-10-30
RS Zakon o porezu na dobit, Sl. glasnik RS 94/15: arts. 31 to 35, 38, 40, 58	https://www.poreskaupravars.org/dokumenti/zakoni/Zakon%20o%20porezu%20na%20dobit%20od%2001_01_2016.pdf	2026-10-30
RS amendment 114/25, in force 1 January 2026: arts. 10, 11, 12, 17 (arts. 34, 35, 40, 58 of the law)	https://poreskaupravars.org/wp-content/uploads/2025/12/Dobit-1.pdf	2026-10-30
RS Pravilnik o transfernim cijenama i metodama za njihovo utvrđivanje, Sl. glasnik RS 47/16: arts. 2 to 13	https://www.poreskaupravars.org/dokumenti/pravilnici/Pravilnik%20o%20transfernim%20cijenama%20i%20metodama%20za%20njihovo%20utvrdjivanje.pdf	2026-10-30
Poreska uprava RS, profit tax secondary legislation in force	https://poreskaupravars.org/pravna-lica/propisi-o-porezu-na-dobit-podzakonski-akti/	2026-10-30
RS Zakon o poreskom postupku, Sl. glasnik RS 78/20: art. 60	https://poreskaupravars.org/wp-content/uploads/2020/11/Zakon-o-poreskom-postupku.pdf	2026-10-30
BD Zakon o porezu na dobit, consolidated text Sl. glasnik BD 17/22: arts. 2(e), 2(j), 8(3), 9	https://skupstinabd.ba/3-zakon/ba/Zakon%20o%20porezu%20na%20dobit/05B17-22%20Zakon%20o%20porezu%20na%20dobit%20-%20prec--is--eni%20tekst.pdf	2026-10-30
BD Zakon o Poreznoj upravi 11/20: art. 68	https://skupstinabd.ba/3-zakon/ba/Zakon%20o%20Poreznoj%20upravi%20Brc--ko%20Distrikta%20BiH/011B11-20%20Zakon%20%20o%20poreznoj%20upravi%20Brcko%20distrikta%20BiH.pdf	2026-10-30

Not yet confirmed: whether the RS Ministry has issued a new transfer pricing rulebook after 114/25 (the Tax Administration's list, updated June 2026, still shows 47/16, so the KM 700,000 annual-return threshold is taken from it; the law's KM 50,000 documentation threshold from 2026 is a separate test); the form number and layout of the RS annual return of controlled transactions; the BD rulebook that sets how market value is found (BD law art. 9(3)), which was not found on an official site; whether a BD transfer pricing adjustment also triggers a general fine under the BD tax administration law; whether the RS Zakon o poreskom postupku art. 115 (30% of an unreported tax) is applied to transfer pricing adjustments; what the FBiH condition that both companies "show transfer prices for the same transaction in their tax base" (Rulebook art. 95(2)(a)) requires of a counterparty that underpaid and so has no adjustment line of its own; the FBiH Ministry of Finance's 2017 position on applying the rulebook (pufbih.ba lists it, but the PDF had no text layer). The RS law and rulebook texts were read from OCR of the official gazette scans published by Poreska uprava RS.

Contributed by Michael Cutajar.