The Serbian Ministry of Finance has opened public consultations on amendments to the Law on Corporate Income Tax, with comments and proposals accepted until 21 June 2026. The reform package is presented as part of a wider effort to align Serbia’s tax framework with European Union legislation while the country progresses with its EU accession agenda. The consultation process is ongoing, and the final legislative text may be adjusted before submission to the National Assembly.
Global minimum corporate tax draft developed alongside
The proposed amendments are being prepared in parallel with a separate draft law on a global minimum corporate tax. The new framework reflects major international tax reforms adopted by the EU and the OECD. Under the proposal, multinational groups and large domestic corporate groups with annual consolidated revenues above €750 million would face a supplementary tax when their effective corporate tax rate drops below 15% in a given jurisdiction.
The measure is designed to mirror the EU’s implementation of the OECD’s Pillar Two rules. It links the supplementary tax obligation to the effective rate outcome in each jurisdiction. The draft law is therefore positioned as a separate track alongside the amendments to Serbia’s existing corporate income tax regime.
Corporate income tax amendments for cross-border restructuring
Alongside the global minimum tax initiative, the amendments to the Corporate Income Tax Law focus on harmonising Serbia’s rules with several EU directives related to cross-border corporate transactions. The changes are intended to support corporate operations that involve companies across different European jurisdictions. These include mergers, demergers, partial divisions, asset transfers, share exchanges and other corporate restructurings.
A stated objective is to build a tax framework closer to those used within the European Union. The approach is aimed at reducing administrative barriers for companies carrying out cross-border investments and corporate restructuring. This is described as relevant for Serbian businesses seeking deeper integration with EU markets, foreign investors viewing Serbia as a regional investment platform, and multinational groups operating across Southeast Europe.
Dividend taxation and reorganisations under consultation draft provisions
The consultation materials also include provisions that change tax treatment for dividend payments and profit distributions between Serbian companies and entities resident in EU member states. Certain dividend-related income would be excluded from the taxable base, reflecting principles already set out in EU parent-subsidiary taxation frameworks. The draft further introduces rules covering cross-border reorganisations.
The published draft provisions also address transitional treatment for existing tax incentives. These elements are included within the broader set of amendments presented during the consultation period. Any final changes would depend on how the legislative text evolves before it is submitted to the National Assembly.
