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Updated 2025 Arm's Length Interest Rates Published

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Serbia
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The Ministry of Finance has adopted the Rulebook on interest rates considered to be in line with the "arm’s length" principle for 2025. The Rulebook was published in the Official Gazette on February 28 and will enter into force on March 8.

Compared to 2024, the changes are as shown in the table below:

For banks and financial leasing providers:

  • Short-term credits in RSD - decrease from 5.02% in 2024 to 3.92% in 2025;
  • Long-term credits in RSD - decrease from 5.16% in 2024 to 0.81% in 2025;
  • EUR credits and credits indexed in EUR - increase from 4.31% in 2024 to 4.59% in 2025;
  • USD credits and credits indexed in USD - increase from 5.02% in 2024 to 5.26% in 2025.

For other companies:

  • Short-term loans in RSD - increase from 7.57% in 2024 to 8.01% in 2025;
  • Long-term loans in RSD - decrease from 8.30% in 2024 to 8.24% in 2025;
  • Short-term EUR loans and loans indexed in EUR - increase from 6.12% in 2024 to 6.41% in 2025;
  • Loan-term EUR loans and loans indexed in EUR - increase from 6.23% in 2024 to 6.79% in 2025;
  • Short-term USD loans and loans indexed in USD - increase from 8.20% in 2024 to 8.31% in 2025;
  • Loan-term USD loans and loans indexed in USD - decrease from 4.25% in 2024 to 3.40% in 2025;

By analysing the differences in interest rates, we conclude that long-term lending within business groups in dinars and US dollars is less tax-advantageous in 2025, with a sharp drop in the tax rate especially for banks and financial leasing providers (from 5.16% last year to 0.81% this year for dinars, and from 4.25% to 3.40% in the case of the US dollar).

Short-term lending in dinars with related parties is also less tax-advantageous for the banks and financial leasing providers. In all other cases, in 2025, slightly higher interest rates will be recognized as interest rates " arm’s length".

Of course, banks and financial leasing providers, as well as all other companies, have the option to apply the general rules on determining the transaction price on the "arm’s length" principle, instead of applying the interest rates prescribed by the rulebook, and then to use the interest rates thus determined for the purposes of the transfer pricing rules.

By Nikola Djordjevic, Partner, JPM Partners

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