Serbia: corporate income tax (porez na dobit pravnih lica), tax year 2026

Source-cited draft: not reviewed by an accountant, not for filing.

The statute is the Zakon o porezu na dobit pravnih lica (ZPDPL), Službeni glasnik RS 25/2001 with amendments up to 80/2026. The Ministry of Finance publishes the Official Gazette's unofficial consolidated text. Article numbers below refer to it.

Read this first: the 2026 amendment. Law 80/2026 entered into force on 8 September 2026. Most of it applies only from the day Serbia joins the EU. A few articles apply from 1 January 2027 and others from 1 January 2028 (Article 23 of the amending law). None of it changes the rates, rules or deadlines for tax year 2026. The articles that apply from 1 January 2027 repeal the 1% withholding on secondary raw materials and waste (amending law Art. 5), the concession-related exemptions in ZPDPL Articles 25a(3) and 30a (Arts. 2 and 3) and the Article 50j start-up credit (Art. 16). The law does not say in so many words whether the repeal of Articles 25a(3) and 30a also reaches a 2026 tax balance filed in 2027; check if a concession transfer arises. This skill uses the text in force before 80/2026 (the version with amendments up to 94/2024) for 2026. It notes where the newer text differs.

See also: serbia-income-tax (individuals, entrepreneurs, paušalci), serbia-vat, serbia-payroll, serbia-social-contributions, how-to-open-a-company-in-serbia-as-a-foreigner-doo-entrepreneur-registration-guide.

Who this applies to

• Resident taxpayers. A legal entity incorporated in Serbia, or with its place of effective management and control in Serbia, is resident. It is taxed on worldwide profit (ZPDPL Article 2).
• Non-residents. A legal entity incorporated and effectively managed outside Serbia is taxed on profit earned through a permanent establishment (PE) in Serbia, unless a tax treaty says otherwise (Article 3).
• What counts as a PE. A PE is any fixed place of business: a branch, plant, representative office, factory, workshop or mine. Building, construction or installation sites count if they last more than six months. A dependent agent who habitually concludes contracts counts too. Storage, display, delivery and preparatory or auxiliary activities do not create a PE (Article 4).
• Non-residents with no PE pay withholding tax on certain Serbian-source income, or tax by assessment on Serbian capital gains (Article 40; see Cross-border points).
• Out of scope or exempt.
  • Entrepreneurs (preduzetnici) and individuals pay personal income tax. Use serbia-income-tax.
  • A non-profit organisation is exempt for a period when its surplus is not more than RSD 400,000 and it meets the conditions in Article 44 (no distribution to founders, capped pay, no dominant market position).
  • A company set up to train, rehabilitate and employ disabled persons is exempt in proportion to their share of the workforce (Article 46).

Rates, bands and thresholds

Item	Rate or amount	Tax year	Source
Corporate income tax rate (proportional and uniform)	15%	2026	ZPDPL Art. 39 (MoF consolidated text)
Capital gains of a resident company	Part of taxable profit, so 15%	2026	ZPDPL Arts. 27 and 30
Withholding: dividends, royalties, interest, rent, listed services paid to non-resident companies	20% (unless a treaty says otherwise)	2026	ZPDPL Art. 40(1)
Withholding: royalties, interest, rent and any services paid to a company in a preferential tax jurisdiction	25%	2026	ZPDPL Art. 40(4)
Tax by assessment: non-resident's capital gains on Serbian assets	20% (unless a treaty says otherwise)	2026	ZPDPL Art. 40(7)
Withholding on payments for secondary raw materials and waste	1%	2026 only; repealed from 1 January 2027	ZPDPL Art. 40 (2024 text); amending law 80/2026 Arts. 5 and 23
Loss carry-forward	5 years	2026	ZPDPL Art. 32
Tax consolidation ownership test	at least 75% direct or indirect control, all members resident	2026	ZPDPL Art. 55
Thin capitalisation: related-party debt	interest deductible on related-party debt up to 4 × equity (10 × for banks and financial leasing companies)	2026	ZPDPL Art. 62 (2024 text)
Non-profit exemption threshold	surplus up to RSD 400,000	2026	ZPDPL Art. 44
Large investment tax holiday	10 years, investment over RSD 1 billion and at least 100 new permanent employees	2026 (repealed from 2028; see Article 22 grandfathering)	ZPDPL Art. 50a (2024 text); 80/2026 Arts. 22 and 23
IP income exemption	80% of qualifying income	2026	ZPDPL Art. 25b
Country-by-country report threshold	consolidated group revenue at least EUR 750 million	2026	ZPDPL Art. 61v
Surcharges, local or trade tax on profit, small-company rate, minimum tax	None in the ZPDPL. Article 39 sets one rate.	2026	ZPDPL Art. 39
Pillar Two	No global minimum tax rules in the ZPDPL. A separate draft Law on Global Minimum Tax on Profit went to public consultation from 1 to 21 June 2026 (Government conclusion of 28 May 2026); adoption not confirmed.	2026	ZPDPL consolidated text

The taxable base

Starting point. The base is taxable profit. It is the profit in the income statement, prepared under IFRS, IFRS for SMEs or the Serbian accounting rules. It is then adjusted in the tax balance (poreski bilans) as the ZPDPL requires (Article 6).

Main add-backs. Article 7a lists costs that are never deductible:

• costs that cannot be documented;
• write-downs of a receivable from a person the company also owes money to, up to that debt;
• gifts to political organisations, and gifts to related parties;
• interest on late payment of taxes, contributions and other public levies;
• enforcement and misdemeanour procedure costs;
• fines, contractual penalties and liquidated damages;
• default interest between related parties;
• costs not incurred for the business.

Capped expenses (Article 15):

• Health, education, science, humanitarian, religious, sports and environmental donations: up to 5% of total revenue, combined. Only donations to recipients registered for those purposes count.
• Investment in culture: up to a further 5% of total revenue.
• Membership fees to chambers, unions and associations: up to 0.1% of total revenue. Fees set by law are deductible as set.
• Representation (entertainment): up to 0.5% of total revenue.

Tax depreciation (Articles 10 and 10a). Tax depreciation replaces accounting depreciation. Fixed assets other than intangibles fall into five groups:

Group	Rate	Method
I (real estate)	2.5%	straight line, asset by asset, on cost; pro rata in the year of acquisition
II	10%	declining balance on the pooled group value
III	15%	declining balance on the pooled group value
IV	20%	declining balance on the pooled group value
V	30%	declining balance on the pooled group value

Declining balance uses cost in year one and the written-down value after that. Intangible assets are written off straight line over the useful life used in the books. Goodwill is not depreciable. If the asset was bought from a related party, the base is the lower of the transfer price and the arm's length price (Article 10a). The Minister of Finance's rulebook classifies assets into groups.

Exempt income.

• Dividends and profit shares that a resident company receives from another resident company are not taxable (Article 25(1)).
• Interest on debt securities issued by the Republic, autonomous provinces, local governments or the National Bank of Serbia is not taxable.
• Up to 80% of qualifying income from registered copyright, related rights and patents can be exempt. The exemption is reduced by the share of qualifying R&D spending (Article 25b).

Foreign dividends. A resident parent includes dividends from a foreign subsidiary in its income. If it has held at least 10% for at least one year without a break, it gets an indirect credit (Articles 52 and 53). The credit covers the subsidiary's foreign profit tax and the withholding tax on the dividend. It is capped at 15% of the grossed-up dividend. Any unused credit carries forward for 5 years. A Serbian participation exemption for EU dividends exists in the 80/2026 text (Article 25(2)), but it applies only from EU accession.

Capital gains and losses (Articles 27 to 30).

• A gain on selling real estate, IP rights, shares and securities, and units in investment funds is part of taxable profit.
• A capital loss can only be set off against capital gains. A loss left over carries forward against future capital gains for 5 years (Article 30).

Interest limitation in 2026. The 2026 rule is thin capitalisation (Article 62, 2024 text). Interest and related costs on loans from related parties are deductible only on the part of the related-party debt that does not exceed four times the company's equity. For banks and financial leasing companies the limit is ten times equity. Equity is the assets that earn income, less the debts linked to them, averaged over 1 January and 31 December. The interest must also be at arm's length (Articles 60 and 61). For 2026 the arm's length interest rates are set by the Minister of Finance's Rulebook on interest rates considered to be at arm's length for 2026 (Sl. glasnik RS 36/2026), made under Article 61(3). It applies to loans and credits between related parties for 2026 (Rulebook Arts. 1 and 2). For the rates, see rs-transfer-pricing.

The 80/2026 law replaces thin capitalisation with a 30% of EBITDA cap (EUR 3 million safe harbour, 3-year carry-forward; Article 62a). That rule applies only from EU accession.

Losses (Articles 32 and 33).

• A tax loss in the tax balance carries forward against taxable profit for up to five years.
• There is no carry-back.
• The relief survives mergers and changes of legal form. On a division it is split in proportion.

Tax consolidation (Articles 55 to 57). A parent and its subsidiaries form a group if the parent controls, directly or indirectly, at least 75% of the shares. All members must be Serbian residents.

• The parent applies to the tax office. It can apply no earlier than the end of the period in which the conditions are met.
• The tax office decides within 30 days.
• Each member still files its own return. The parent also files a consolidated tax balance. Current-year losses of one member are set off against the profits of the others.
• A member's own losses brought forward cannot be used inside the consolidated balance.
• The tax is borne by members in proportion to their individual taxable profit.
• Consolidation must last at least five years. If it ends early, the members repay the benefit they received.

Investment incentives. The 10-year holiday for large investments (Article 50a) and the 30% credit for investing in innovative start-ups (Article 50j) still apply in 2026.

• Law 80/2026 repeals Article 50j from 2027. Taxpayers who meet its conditions by the end of their 2026 tax period keep the benefit.
• It repeals Articles 50a to 50i from 2028. Taxpayers who meet the Article 50a conditions by the end of their 2027 tax period keep the benefit (80/2026 Articles 22 and 23).

Deadlines and filing

• Tax period. The tax period is the business year, which is the calendar year. A company can get approval for a different business year (Article 38).
• Annual return. The company files the corporate income tax return (PDP) with the tax balance within 180 days after the end of the tax period. For a calendar year 2026 that is 29 June 2027. A return filed without the tax balance counts as not filed (Article 63). The form's content is set by the Pravilnik o sadržaju poreske prijave za obračun poreza na dobit pravnih lica.
• Final payment. Any tax still due after advances must be paid by the time the return is filed (Article 66). If advances were too high, the excess counts toward the next period or is refunded on request.
• Monthly advances (akontacije). Advances are based on the previous year's taxable profit, excluding capital gains and losses, as shown in last year's return. Each month's advance is due by the 15th of the next month (Article 67).
  • Until the new return is filed, the company keeps paying the advance from the last month of the previous period.
  • After the new return is filed, advances are trued up so that the year-to-date total matches the new amount.
  • If business changes a lot, the company can file to change its advances (Article 68).
• New companies. A new company files an opening return with estimated profit within 15 days of registration. This sets its monthly advance (Article 64).
• Status changes. If a company ceases to exist in a merger or division, its successor files within 60 days of registration of the change (Article 63).
• E-filing. Corporate income tax returns have been filed electronically through the Tax Administration portal (ePorezi) since 1 April 2015. Withholding tax returns have been filed electronically since 1 March 2016 (Tax Procedure Law, Article 38).
• Withholding tax. The payer withholds and pays the tax within three days of paying the income, and files a withholding return in the same three days (Articles 40(6) and 71).

Penalties and interest

The penalties and interest come from the Zakon o poreskom postupku i poreskoj administraciji (ZPPPA, Tax Procedure and Tax Administration Law). The penalties below are the amounts for legal entities.

• Late-payment interest (ZPPPA Article 75). The rate is the National Bank of Serbia's annual reference (key policy) rate plus 10 percentage points. The key policy rate was 5.75% when read on 2026-10-22 (held at 5.75% on 10 September 2026 and again on 8 October 2026), so late-payment interest is 15.75% a year until the NBS changes its rate. Each change of rate starts a new calculation period. It is simple interest on actual days over a 365 or 366 day year, running from the day after the due date. Unpaid monthly advances attract the same interest (ZPDPL Article 67). Interest on late tax is not deductible (ZPDPL Article 7a).

• Return not filed and tax not calculated or paid. The fine is 30% to 100% of the tax due, and at least RSD 500,000 (ZPPPA Article 177(1)).

• Return not filed but tax paid on time. The fine is RSD 100,000 to 2,000,000 (Article 177(5)).

• Return filed late and tax not paid on time. Fixed fines depend on the tax due:

  Tax due	Fine
  Up to RSD 100,000	RSD 25,000
  RSD 100,000 to 1,000,000	RSD 50,000
  RSD 1,000,000 to 10,000,000	RSD 200,000
  Over RSD 10,000,000	RSD 300,000

  If the return is filed late but the tax is paid on time, the fine is RSD 100,000 (Article 177(8) and (9)).

• Return filed on time and tax not paid on time. The fine is RSD 20,000 to 250,000 on the same scale (Article 177(10)).

• Under-declaration or incorrect data. The fine is 30% to 40% of the tax difference, and at least RSD 200,000. If the difference is up to 5% of the correct tax, the fine is RSD 100,000 (ZPPPA Article 178).

• Other cases found in a tax audit (Article 177(2) to (4)). Return not filed and tax not calculated: 20% to 65%, at least RSD 300,000. Return not filed, tax calculated but not paid: 20% to 75%, at least RSD 400,000. Return filed but tax not paid: 10% to 50%, at least RSD 250,000.

• Responsible person. The responsible person in the company is fined separately, usually RSD 10,000 to 100,000.

Cross-border points

Withholding on outbound payments (ZPDPL Article 40). Unless a treaty says otherwise, 20% is withheld on these payments by a resident company to a non-resident company:

• dividends and profit shares;
• royalties;
• interest;
• rent for immovable and movable property in Serbia;
• market research, accounting, audit, legal and business consulting services, wherever they are performed.

Performers' and sportsmen's fees are also covered if they are not taxed as an individual's income.

Preferential tax jurisdictions. A company from a jurisdiction on the Minister of Finance's list (Article 3a) suffers 25% on royalties, interest, rent and all services, wherever performed. Dividends to such a company stay at 20%. Interest on Serbian government, provincial, municipal and National Bank debt securities is exempt.

Treaty relief (Article 40a). The payer may apply the treaty rate at the time of payment. To do so it must hold a certificate of residence for the recipient, and the recipient must be the beneficial owner. If the payer does not have the certificate when it pays, it withholds at the domestic rate. If the certificate arrives later, the difference is treated as overpaid tax.

Capital gains of non-residents. A non-resident company's gains on Serbian assets are taxed at 20% by assessment. It files through a tax proxy within 30 days.

Payments to a Serbian PE. No withholding applies to payments to a Serbian PE of a non-resident, unless the PE belongs to a company from a preferential tax jurisdiction (Article 40(12) and (13)).

Foreign tax credits. A resident gets a credit for foreign tax on profit earned through a foreign PE, capped at the Serbian tax on that profit (Article 51). It also gets a credit for foreign withholding tax on interest, royalties, rent, services and dividends that do not qualify for Article 52 (Article 53a).

Transfer pricing (Articles 59 to 61v).

• Related parties. These include holdings or voting rights of at least 25%, the listed family relationships, and any company from a preferential tax jurisdiction.
• Reporting. Related-party transactions must be shown separately in the tax balance and priced at arm's length. Supporting documentation is set by a Minister of Finance rulebook.
• Country-by-country reporting. A Serbian ultimate parent of a group with at least EUR 750 million consolidated revenue files a country-by-country report within 12 months of year end.
• Detail. Methods, documentation and the 2026 arm's length interest rates are in rs-transfer-pricing.

CFC rules and exit tax. For tax year 2026 Serbia has neither CFC rules nor an exit tax on companies. Law 80/2026 adds both under the new heading "Rules against profit shifting": CFC rules (ZPDPL Articles 62b and 62v), exit taxation (Article 62g) and hybrid mismatch rules (Articles 62d to 62z). Amending law Article 18 inserts them after Article 62, which amending law Article 17 deletes. Article 23 of Law 80/2026 says the law applies from the day Serbia joins the EU, except amending Articles 2, 3, 5, 6, 8, 16 and 19 (from 1 January 2027) and Articles 9 to 15 (from 1 January 2028). The articles that delete Article 62 and insert these rules are not on either list. So the CFC, exit tax and hybrid mismatch rules apply from the day Serbia joins the EU, and not in 2026, 2027 or 2028. The same law adds a general anti-abuse rule (ZPDPL Article 111a, inserted by amending law Article 20). Article 20 is not on either list either, so Article 111a also applies only from the day Serbia joins the EU. Amending law Article 19, which applies from 1 January 2027, only changes a cross-reference in Article 71(1).

Worked examples

Example 1: trading company, calendar year 2026

Morava Trade d.o.o. is a Belgrade wholesaler with no related-party debt. Its 2026 figures:

• Total revenue: RSD 100,000,000.
• Accounting profit before tax: RSD 12,000,000.
• Traffic and other fines in the books: RSD 150,000. These are not deductible, so the whole amount is added back.
• Representation: RSD 900,000. The cap is 0.5% × 100,000,000 = RSD 500,000, so RSD 400,000 is added back.
• Accounting depreciation: RSD 2,000,000. Tax depreciation under the group rates: RSD 1,600,000. The difference of RSD 400,000 is added back.

Taxable profit is 12,000,000 + 150,000 + 400,000 + 400,000 = RSD 12,950,000. Tax at 15% is RSD 1,942,500.

Monthly advances paid during 2026 total RSD 1,700,000. The balance of RSD 242,500 must be paid by the time the PDP return is filed, on 29 June 2027 at the latest.

name: Example 1, Serbian trading company, tax year 2026
inputs:
  revenue: 100000000
  accounting_profit: 12000000
  fines: 150000
  representation: 900000
  book_depreciation: 2000000
  tax_depreciation: 1600000
  advances_paid: 1700000
steps:
  - representation_cap: revenue * 0.005
  - representation_addback: max(representation - representation_cap, 0)
  - depreciation_addback: book_depreciation - tax_depreciation
  - taxable_profit: accounting_profit + fines + representation_addback + depreciation_addback
  - tax: taxable_profit * 0.15
  - balance_due: tax - advances_paid
expected:
  representation_cap: 500000
  representation_addback: 400000
  taxable_profit: 12950000
  tax: 1942500
  balance_due: 242500

Example 2: losses brought forward, one of them expired, and an exempt Serbian dividend

Drina Tech d.o.o. has a calendar tax year.

• 2026 accounting profit: RSD 5,800,000. This includes a dividend of RSD 800,000 from a Serbian resident subsidiary. That dividend is not taxable (Article 25(1)), so it is deducted.
• No other adjustments.
• Unused tax losses: RSD 1,200,000 from 2020 and RSD 3,000,000 from 2023.

A loss can only be carried forward for five years (Article 32). The 2020 loss could be used in 2021 to 2025, so it has expired and cannot be used in 2026. The 2023 loss is still available.

Taxable profit before losses is 5,800,000 − 800,000 = RSD 5,000,000. The 2023 loss covers RSD 3,000,000 of it. That leaves RSD 2,000,000, and tax at 15% is RSD 300,000.

Advances for 2027 are based on the 2026 taxable profit shown in the return. Ask the client whether their tax software treats that figure as before or after the losses brought forward. The law says advances are based on taxable profit "shown in the return for the previous year". Check the PDP form line before you set the monthly figure.

name: Example 2, loss carry-forward with an expired 2020 loss and an exempt resident dividend
inputs:
  accounting_profit: 5800000
  resident_dividend: 800000
  loss_2020: 1200000
  loss_2023: 3000000
steps:
  - profit_before_losses: accounting_profit - resident_dividend
  - usable_losses: min(loss_2023, profit_before_losses)
  - taxable_profit: profit_before_losses - usable_losses
  - tax: taxable_profit * 0.15
  - loss_2020_lost: loss_2020
expected:
  profit_before_losses: 5000000
  usable_losses: 3000000
  taxable_profit: 2000000
  tax: 300000
  loss_2020_lost: 1200000

Ask the client first

1. Is the company Serbian-incorporated or managed in Serbia, or is it a foreign company with a branch, site or agent in Serbia? Has a construction site lasted more than six months?
2. Does it borrow from, lend to, buy from or sell to related parties, including any company on the preferential tax jurisdiction list? What is its equity under the Article 62 definition?
3. Does it own at least 75% of other Serbian companies, and has it applied for tax consolidation?
4. What tax losses and capital losses does it have, and from which years?
5. Does it pay dividends, interest, royalties, rent or consulting fees abroad? Does it hold residence certificates for the recipients?
6. Does it claim an incentive: the Article 50a investment holiday, the Article 50j innovation credit, or the IP exemption? When were the conditions met?

Sources

Source	URL	Read on
Ministry of Finance: Zakon o porezu na dobit pravnih lica, Official Gazette consolidated text with amendments up to 80/2026 (page and .docx)	https://www.mfin.gov.rs/propisi/zakon-o-porezu-na-dobit-pravnih-lica ; https://www.mfin.gov.rs//upload/media/SByOge_6aa127acd2250.docx	2026-10-23
Ministry of Finance: the same law, consolidated text with amendments up to 94/2024 (the version that applies to tax year 2026), .docx still hosted by the Ministry	https://www.mfin.gov.rs/upload/media/vlmAb4_675ab2034cea0.docx	2026-10-22
Ministry of Finance: Zakon o poreskom postupku i poreskoj administraciji, consolidated text with amendments up to 80/2026 (page and .docx)	https://www.mfin.gov.rs/propisi/zakon-o-poreskom-postupku-i-poreskoj-administraciji-0809 ; https://www.mfin.gov.rs/upload/media/2UkJa3_6a9fe325297c3.docx	2026-10-22
Tax Administration: corporate income tax law page (lists amendments up to 80/26)	https://www.purs.gov.rs/sr/pravna-lica/porez-na-dobit/zakon-pdp/306/zakon-o-porezu-na-dobit-pravnih-lica.html	2026-10-22
Tax Administration: Rulebook on the content of the corporate income tax return (Sl. glasnik 30/15 to 21/25)	https://www.purs.gov.rs/sr/pravna-lica/porez-na-dobit/podzakonska-akta-pdp/6861/pravilnik-o-sadrzaju-poreske-prijave-za-obracun-poreza-na-dobit-pravnih-lica.html	2026-10-22
National Assembly: Law 80/2026 amending the ZPDPL, adopted text (Arts. 17 to 20 and 23)	https://www.parlament.gov.rs/upload/archive/files/lat/pdf/zakoni/14_saziv/2559-26%20-%20Lat..pdf	2026-10-23
Ministry of Finance: Rulebook on arm's length interest rates for 2026 (Sl. glasnik RS 36/2026), page and .docx	https://www.mfin.gov.rs/propisi/pravilnik-o-kamatnim-stopama-za-koje-se-smatra-da-su-u-skladu-sa-principom-van-dohvata-ruke-za-2026-godinu-slubeni-glasnik-rs-br-362026 ; https://www.mfin.gov.rs/upload/media/aatf8h_69f0810128819.docx	2026-10-23
Tax Administration: corporate income tax secondary legislation list (arm's length interest rate rulebooks, preferential jurisdictions list, transfer pricing rulebook)	https://www.purs.gov.rs/sr/pravna-lica/porez-na-dobit/podzakonska-akta-pdp.html	2026-10-22
National Bank of Serbia: key policy rate (home page rate panel and the 10 September 2026 decision)	https://www.nbs.rs/en/indeks/ ; https://nbs.rs/en/scripts/showcontent/index.html?id=21715	2026-10-22
Government of Serbia conclusion of 28 May 2026 opening public consultation on the draft Law on Global Minimum Tax on Profit (hosted by the Ministry of Finance)	https://www.mfin.gov.rs//upload/media/thb1x7_6a198d07e3278.pdf	2026-10-22
Pravno-informacioni sistem RS: ELI record of the ZPDPL. The ELI resolves, but the text sits behind a login and could not be read, so no figure here relies on it.	https://www.pravno-informacioni-sistem.rs/SlGlasnikPortal/eli/rep/sgrs/skupstina/zakon/2001/25/1/reg	2026-10-22

Not yet confirmed: whether the draft Law on Global Minimum Tax on Profit (consultation June 2026) has been adopted, and from when it applies; whether the 1 January 2027 repeal of ZPDPL Articles 25a(3) and 30a applies to the 2026 tax balance; the exact form codes of the return and tax balance under the 21/25 rulebook (the Tax Administration labels the return "PDP"); the asset-to-group classification in the depreciation rulebook.

Contributed by Ryan Duguid.