Corporate Income Tax

The primary objectives of our training programs are to address practical problems and situations encountered by clients and managers, as well as to develop skills for independently handling complex tasks in the field of corporate income tax, preparing fully compliant tax balance sheets, and completing tax returns along with all accompanying attachments.

Program Content

• Latest amendments in corporate income tax regulations

• Taxable profit as a starting point – definitions of income and expenses

• Risks of improper recognition and reporting of income and expenses

• Documentation of expenses – Article 7a of the Corporate Income Tax Law

• Expenses not incurred for the purpose of business operations

• Treatment of value adjustments and write-offs of receivables – practical examples

• Calculation of tax depreciation / acquisition of assets from related parties – practical examples

• Other expense adjustments

• Revenue alignment

• Experiences from tax audits and tax practice

• Opportunities for tax optimization

Benefits for Participants

• Familiarization with new regulations and opinions of the Ministry of Finance

• Training for independent preparation and review of tax balance sheets, tax returns, and attachments

• Better understanding of corporate income tax legislation through examples and practice

• Resolution of practical questions through discussions with the consulting team

• Avoidance of double taxation

Double Taxation Agreements (DTA)

Program Content

• DTAs in effect – signed and initialed new agreements, agreements under negotiation, and upcoming negotiations

• Multilateral Convention and its impact on existing and new DTAs

• Current status of amended DTAs under the Multilateral Convention

• Determining resident status under DTAs

• Copyright vs. services under withholding tax rules

• Will the application of the Multilateral Convention affect domestic legislation?

Benefits for Participants

• Familiarization with new DTAs and Ministry of Finance opinions

• Assessment of opportunities for business optimization using DTA benefits

• Proactive approach to business planning

• Identification of potential risks regarding withholding taxes

• Clarification of practical DTA application

Tax Challenges in the Digital Economy

The digital economy presents significant challenges for existing tax regulations, which must adapt to new business concepts without hindering further digital business development.

Key challenges include:

• Reduced need for a physical presence for business operations

• Companies’ ability to generate and process growing volumes of data

• Development of digital products and new service distribution methods

• Impact of digital trade on VAT collection

Program Content

• Tax challenges in the digital economy and recent regulatory changes

• Tax benefits for IT companies: investment tax credits for startups, R&D incentives, tax reductions on license revenues

• Tax treatment of license acquisitions from the perspective of withholding tax and VAT

• Taxation of flat-rate businesses – risks and opportunities

• Opportunities for tax optimization

• Intercompany transactions – transfer pricing

Benefits for Participants

• Understanding the tax environment in digital business

• Ability to independently identify tax risks and optimization opportunities

• Familiarization with new regulations and Ministry of Finance opinions

• Resolution of practical questions through discussion with the consulting team

Preparing for a Tax Audit

Program Content

• Will tax administration reform lead to substantive changes in taxpayer relations?

• Rights and obligations of taxpayers during audits

• Advantages and risks of initiating a tax audit

• Participation of companies vs. employees in audits

• When to involve a tax advisor in filing appeals or responding to audit notices

Benefits for Participants

• Familiarity with specifics of the tax audit process, taxpayer rights, and obligations

• Awareness of announced changes in tax administration

• Understanding audit requests based on extensive audit experience

• Using internal regulations to reduce risks

• Independent assessment of tax risks

• Resolving practical issues through consultation

Personal Income Tax

Personal income tax, together with mandatory social security contributions, accounts for about 37% of Serbia’s total budget revenues. Payment of taxes and contributions is sensitive, as employees’ rights depend on these payments. Increasing the tax base by disallowing certain expenses usually does not justify excluding them from personal income tax. Since personal income tax is a withholding tax, failure to calculate or pay it constitutes a separate tax offense. This explains why income tax is often a focus during audits, extending some corporate income tax and VAT audits to income tax.

Program Content

• Taxation of income in Serbia and abroad – strategies for income tax optimization

• Engagement of directors and board members without remuneration

• Changes in flat-rate taxation

• Taxation of non-residents earning income in Serbia and residents earning abroad

• Non-deductible expenses and their taxation under personal income tax

Benefits for Participants

• Familiarity with expected changes in personal income tax regulations

• Identification of potential risks for your company

• Opportunities for tax optimization

• Resolution of current uncertainties through experience sharing with consultants and peers

Value Added Tax (VAT)

Interest in VAT is steadily growing due to opposing interests between multinational companies seeking cash flow optimization and national governments relying on VAT as a major revenue source (e.g., approximately 50% of Serbia’s tax revenue comes from VAT).

Program Content

• VAT regulations in Serbia vs. EU legislation – key differences

• Recent developments in VAT

• Expected amendments in the near future

• Application of recently enacted VAT regulations

• Tax and judicial practice

• Open questions without official positions from the Tax Administration or Ministry of Finance

Benefits for Participants

• Understanding the current VAT landscape in Serbia and the EU

• Preparation for upcoming changes in VAT regulations

• Clarification of practical application issues

• Awareness of open questions that may affect your business

BEPS (Base Erosion and Profit Shifting)

BEPS regulations by the OECD aim to prevent tax planning that exploits inconsistencies in national laws, reduces taxable bases, and shifts profits artificially to low-tax jurisdictions. In June 2017, 76 countries (including Serbia) signed the Multilateral Instrument in Paris to amend double tax treaties. BEPS actions affecting domestic laws include preventing artificial permanent establishment avoidance, base erosion through debt, misuse of treaty benefits, digital economy tax challenges, and dispute resolution improvements.

Program Content

• Overview of BEPS actions: already implemented in Serbia vs. upcoming

• Application of the Multilateral Instrument: changes to double taxation treaties

• Thin capitalization rules

• Permanent establishment regulations

• Transfer pricing regulations

• Digital taxation

Benefits for Participants

• Application of BEPS provisions in tax decisions

• Understanding implemented and anticipated changes in Serbian tax regulations

• Assessing BEPS impact on your company

• Understanding globalization and new technology effects on taxation

Transfer Pricing

The highly dynamic global business environment and pressure from tax authorities to maximize revenue make transfer pricing a top financial and tax priority. Understanding intercompany transaction implications is crucial.

Program Content

• Concept and legal framework of transfer pricing

• Relevant laws (direct and indirect sources)

• OECD Transfer Pricing Guidelines

• Arm’s length principle

• Identification of related parties and transactions – practical examples

• Value chain analysis

• Functional analysis: significance of activities, assets, and risks

• Intercompany transactions: materials, goods, real estate, services, intangibles

• Comparability analysis – practical examples

• Interest “at arm’s length” and adjustments

• Transfer pricing methods – selection and application

• Practical exercises with databases, profit indicators, and adjustments

Benefits for Participants

• Training to independently analyze and conclude on intercompany compliance

• Expert insights on over 30 intercompany cases

• Full materials including functional analysis models, adjustments, and interest calculations

• Resolution of practical issues with consultant support

• Ongoing support from a consulting team with over 400 transfer pricing studies across 500 engagements

IFRS 15 & IFRS 16 – Tax Aspects

Program Content

• Reasons and objectives for new standards – IFRS 15 (Revenue from Contracts with Customers) and IFRS 16 (Leases)

• Start of application in Serbia

• Overview of major changes vs. previous standards

• Impact on daily business operations

• Financial statement structure and results

• Tax implications of new standards

Benefits for Participants

• Timely preparation for new standards

• Familiarity with key changes

• Assessment of impact on daily operations

• Understanding tax effects of new standards