Arm’s-Length Interest Rates for 2025

Acting on the basis of the authority granted by Article 61, paragraph 3 of the Corporate Income Tax Law, the Minister of Finance of the Republic of Serbia adopted the Rulebook on Interest Rates Deemed to Be at Arm’s Length for 2025.

The Rulebook prescribes interest rates relevant for determining corporate income tax obligations in 2025. These rates may also be used when calculating withholding tax in situations where interest income is paid to a related non-resident legal entity.

The prescribed interest rates apply not only to classic loans, but also to other forms of financing between related parties, ensuring a uniform tax approach to such transactions.

For banks and financial leasing providers, the prescribed rates include:

• 3.92% on short-term loans in RSD
• 0.81% on long-term loans in RSD
• 4.59% on loans in EUR and RSD loans indexed to EUR
• 5.26% on loans in USD and RSD loans indexed to USD
• 2.75% on loans in CHF and RSD loans indexed to CHF
• 4.09% on loans in SEK and RSD loans indexed to SEK

In transfer pricing practice, these rates are important whenever related-party financing exists and the taxpayer relies on the prescribed arm’s-length interest rates instead of a separate benchmark study.