Governor of the National Bank of Serbia (NBS), Jorgovanka Tabaković, has accused retail chain Delhaize Serbia of staging a fictitious liquidation procedure in order to transfer €130 million of profit out of the country without paying taxes. Delhaize, however, firmly rejects these allegations as false.
Speaking at a press conference, Tabaković said that Delhaize has been generating significant profits in Serbia.
“At one point, we learned that Delhaize was due to pay out €120–130 million. We assumed this represented profit—logically, it should be distributed as dividends and taxed in Serbia. The transaction took place, but in the dividend report this amount was missing. Instead, we received a different code: payment of liquidation proceeds,” she stated.
According to Tabaković, Delhaize then established a new company at the same address as its parent firm in Belgium, held it for five months, and transferred the €130 million to that entity without paying a single dinar in taxes to Serbia. She claimed that the company “fabricated a liquidation process” solely to move profits abroad tax-free.
Delhaize responds
Delhaize strongly denies the accusations.
“All steps related to the status changes—including the spin-off, capital transfer and the subsequent liquidation of the newly established entity in 2021—were carried out in accordance with the laws of the Republic of Serbia and in consultation with an internationally recognized auditing and tax advisory firm,” the company said.
Delhaize added that the Serbian Tax Administration reviewed the transaction in 2022 and issued a ruling reclassifying the capital transfer as a dividend distribution.
“In full compliance with that decision, Delhaize Serbia paid €7 million in dividend tax, despite disagreeing with the Tax Administration’s interpretation, which is why we filed a formal appeal on 1 April 2022,” the company stated. The appeal process, they noted, is still ongoing.
“Public statements accusing our company of violating the law and avoiding tax payments contradict our culture of transparent and responsible business conduct,” Delhaize said. “Delhaize Serbia is the largest private-sector employer and one of the biggest taxpayers in the country. Such unfounded and misleading claims can damage the business environment and undermine trust in institutions,” the statement concluded.
