This guide provides an in-depth review of Serbia’s corporate tax regime as it stands in 2025. It focuses on the flat corporate tax rate, assessment basis, and rules applicable to both resident and non-resident companies according to the latest officially available data.
Corporate Tax Framework in Serbia
Serbia applies a straightforward, flat-rate corporate tax system. All companies, irrespective of their size or business activities, are subject to the same statutory rate for corporate profits. This approach aims to provide clarity and predictability for both domestic and international business operators.
Standard Corporate Tax Rate (2025)
The tax rate is imposed on a corporate assessment basis. All taxable profits generated by Serbian resident companies, and certain profits earned by non-residents, fall under this regime for the year 2025.
| Tax Type | Rate (%) | Currency Code |
|---|---|---|
| Standard Corporate Tax Rate | 15% | RSD |
Serbia uses the dinar (RSD) as its official currency. For international context, based on an average rate of 1 USD = 110 RSD (indicative for example purposes), the statutory rate remains 15% of corporate profits, regardless of the profit amount or bracket.
Corporate Tax Calculation and Assessment
Under the flat rate system, there are no progressive brackets or tiered rates. The entire taxable profit is subject to the same rate, simplifying the administrative aspects of corporate taxation. Corporate tax is assessed only at the entity level; shareholders are generally taxed separately on dividends or distributions, if any.
Special Regime: Surtax on Capital Gains for Non-Residents
Non-resident companies face an additional layer of taxation when realizing capital gains from Serbian sources. Unless modified by an existing double tax treaty, a surtax is applied. The specifics are shown in the table below.
| Transaction | Surtax Rate (%) | Condition | Currency Code |
|---|---|---|---|
| Capital gains (by non-residents) | 20% | Unless reduced by a double tax treaty | RSD |
This means that any capital gains realized by foreign entities—unless treaty-relieved—will be subject to an additional 20% tax, calculated on the capital gain amount. The duration of the holding period is not a determining factor in the application of this surtax, as current data on holding period requirements is not publicly available.
Summary Table: Serbia Corporate Tax Regime (2025)
| Aspect | Details |
|---|---|
| Assessment Basis | Corporate (entity-level taxation) |
| Rate Type | Flat |
| Standard Rate | 15% (RSD) |
| Capital Gains Surtax (Non-Residents) | 20% (RSD), unless reduced by DTT |
| Holding Period Requirements | No data available |
Key Insights for International Businesses
Serbia’s corporate tax regime stands out for its simplicity. The flat rate structure can lead to predictable tax planning, while the additional tax on capital gains for non-residents introduces an important consideration for cross-border investors. For more detailed or case-specific information, consult the official Serbian Tax Administration website.
Pro Tips: Navigating Serbian Corporate Taxes
- Plan for Capital Gains Surtax: If you operate as a non-resident entity or plan to dispose of Serbian assets, review all applicable double tax treaties to ensure you do not pay surtaxes unnecessarily.
- Optimize Group Structures: With a flat 15% rate, the benefits of creative profit-shifting or bracket-minimizing schemes are limited—but careful structuring can still reduce exposure to the 20% non-resident capital gains surtax.
- Document Everything: Ensure all cross-border transactions and capital gains are robustly documented to validate treaty claims or withholding tax rates to authorities.
- Track Regulatory Changes Annually: While the flat rate system is stable, legal and administrative updates can occur. Monitoring official publications remains essential.
To summarize, Serbia’s corporate tax rules in 2025 rely on a flat 15% tax rate for all companies, complemented by a 20% capital gains surtax for non-resident corporations where treaties do not apply. There are no progressive brackets or holding period criteria disclosed in current data. International investors should closely review treaty positions and maintain strong compliance practices to avoid unnecessary tax costs.