The Rulebook on Amendments to the Rulebook on transfer pricing and methods that are applied according to the arm’s length principle in determinations of transaction prices between related parties was published in the "Official Gazette of RS", No. 95 of October 1, 2021.

The aim of adopting the New Rulebook is reflected in determining the conditions, content and manner of submitting the annual report on controlled transactions of an international group of related legal entities, ie. annual report (so-called "Country-by-Country report" or "CbC report").

This Rulebook entered into force on the eighth day from the day of its publication in the "Official Gazette of the Republic of Serbia", ie on October 9, 2021.

The new Rulebook envisages another element that should be included in the analysis of the group within the transfer pricing report, namely information on whether the taxpayer is a member of an international group of related legal entities and whether it is considered the ultimate parent legal entity in terms of Article 61c of the Law, that is information on the identity and country of residence of the ultimate parent legal entity if the taxpayer is not considered the ultimate parent legal entity.

The very provisions regarding the obligation of the resident ultimate parent legal entity of the international group of related parties, as well as the content of the annual report are prescribed in the newly adopted Art. 32 and 33 of the New Rulebook, and it also contains the form of the annual report which consists of three tables and which will, in the prescribed cases, be submitted in paper form.

The new rules introduced by the amendments to the previously valid rulebook will not affect all corporate taxpayers, nor all taxpayers who are required to compile a report on transfer prices in full. Obligations provided by the new rules refer to the ultimate parent legal entity, when that legal entity is a resident of Serbia, if it is an international group as defined by the provisions of Article 61c of the Law.