The National Assembly of Serbia adopted amendments to the Corporate Income Tax Law on 26 October 2026, introducing significant changes to deductible expenses, loss carryforward rules, and investment incentives. The amendments aim to align domestic legislation with OECD BEPS recommendations and EU directives. Key modifications include a limitation on interest deductibility to 30% of EBITDA, expanded tax credits for R&D activities, and a new regime for carryforward of tax losses up to 10 years. The changes generally apply to tax periods beginning on or after 1 January 2027, with transitional provisions for existing arrangements.
Key Takeaways
- Interest Limitation Rule: Net interest expense deductions are capped at 30% of tax EBITDA, with a de minimis threshold of EUR 3 million. This aligns with EU ATAD II.
- Enhanced R&D Incentives: Taxpayers can claim a 200% deduction for qualified R&D expenditures and a tax credit of up to 30% for innovation projects.
- Loss Carryforward Extension: Tax losses may now be carried forward for 10 years (previously 5), but annual utilization is limited to 50% of taxable profit.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement