Taxation News – Tax Procedure Code

Taxation News – 8th Issue (December 2015)-Tax Procedure Code


  • Amendments to the Tax Procedure Code (C.T.P.) regarding:
    A. Transfer Pricing penalties
    B. Penalties for the inaccurate filing / non-filing of a tax return
    C. Penalties on V.A.T. infringements
    D. Penalties on infringements regarding withholding taxes

On 17 October 2015, Law 4337/2015 introduced amendments which seek the decrease of the
penalties imposed by the Tax Procedure Code.

A. Transfer Pricing penalties

The penalties imposed for the delayed filing / non-filing / filing of inaccurate Summary Information
Table and for the delayed submission / non-submission of the Transfer Pricing Documentation
File are decreased under the new legislation. Moreover, the said penalties are not calculated on
the legal person’s gross profits, but on the value of the intra-group transactions. Specifically:

T.P. Infringements


Amount of penalty Prerequisites for

penalties imposition

Delayed submission of Summary

Information Table

1/1000 of value of the intra-group

transactions (not lower than 500 €

and not higher than 2.000 €)

Submission of inaccurate Summary

Information Table

If the inaccuracy is higher than 10%

of the transactions

Delayed submission of the

amending Summary Information


If the difference from the amended

transactions exceeds 200.000 €

Non-submission of the Summary

Information Table


1/1000 of value of the intra-group

transactions (not lower than 2.500 €

and not higher than 10.000 €)

Delayed submission / non-

submission of the T.P.

Documentation File (after the expiry

of the one month deadline)

5000 Between the 31-60 day
10000 Between the 61-90 day
20000 After the 90 day or non submission


  • Amendments and new provisions to the Tax Legislation regarding:
    A. The regulation of 100 instalments (‘doses’)
    B. The V.A.T. imposition on educational services
    C. The non-recovered income from the lease of real estate property


  • The tax treatment of the capital gain of immovable property


  • The answer on how the new government is going to deliver on election promises


  • Applicable tax to the distributed dividends starting with 1 January 2016


  • The Serbian parliament has adopted the amendments of the Value Added Tax Law whereas their provisions will be coming into effect successively by 1 January, 2017 while Serbian Ministry of Finance has issued an Opinion regarding the V.A.T. status of return of the unsold merchandise


  • V.A.T. – deduction of input value


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