The Serbian Ministry of Finance has launched public consultations on amendments to the Law on Corporate Income Tax, with comments and proposals accepted until 21 June 2026. The reform package forms part of a broader effort to align Serbia’s tax framework with European Union legislation as the country advances its EU accession agenda.
The proposed amendments are being developed in parallel with a separate draft law introducing a global minimum corporate tax, reflecting major international tax reforms adopted by the EU and the OECD. Under the proposed global minimum tax framework, multinational groups and large domestic corporate groups with annual consolidated revenues exceeding €750 million would be subject to a supplementary tax whenever their effective corporate tax rate falls below 15% in a particular jurisdiction. The measure mirrors the EU implementation of the OECD’s Pillar Two tax rules.
Alongside the global minimum tax initiative, the amendments to the existing Corporate Income Tax Law focus primarily on harmonization with several key EU directives governing the taxation of cross-border corporate transactions. The changes are designed to facilitate mergers, demergers, partial divisions, asset transfers, share exchanges and corporate restructurings involving companies operating across different European jurisdictions.
A central objective is to create a tax framework that more closely resembles those used within the European Union, reducing administrative barriers for companies engaged in cross-border investments and corporate restructuring. This alignment is particularly important for Serbian businesses seeking deeper integration with EU markets, foreign investors considering Serbia as a regional investment platform, and multinational groups operating across Southeast Europe.
Draft provisions published during the consultation process also introduce tax treatment changes 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 established within EU parent-subsidiary taxation frameworks. The draft further introduces provisions covering cross-border reorganizations and transitional treatment of existing tax incentives.
For investors, the significance of these reforms extends beyond technical tax compliance. Serbia is gradually positioning its corporate tax regime to operate under the same principles increasingly applied throughout the EU single market. Combined with the forthcoming global minimum tax rules, the reforms signal a shift toward greater transparency, reduced opportunities for aggressive tax planning, and stronger alignment with international tax governance standards.
The consultation process remains ongoing, and the final legislative text may still be amended before submission to the National Assembly. However, the direction is clear: Serbia’s corporate tax framework is moving closer to EU norms at a time when multinational companies, investors, and exporters are increasingly assessing tax structures, compliance obligations, and cross-border investment strategies through the lens of future EU integration.
