New Rulebook on Arm’s Length Interest Rates for 2026
As of 2 May 2026, the Rulebook on Interest Rates Deemed to Be in Compliance with the Arm’s Length Principle for 2026 (“Official Gazette of the Republic of Serbia”, No. 36/2026) shall apply, prescribing interest rates which, in accordance with the arm’s length principle, are used for the calculation of interest on loans and credits between related parties.
Key highlights:
- The Rulebook prescribes reference interest rates for 2026 applicable to banks and financial leasing providers, as well as to other companies, depending on the currency and maturity of the loan.
- For banks and financial leasing providers, the prescribed rates include, inter alia, 4.40% for short-term loans in RSD, 0.33% for long-term loans in RSD, and rates ranging from 1.50% to 10.73% for loans denominated in foreign currencies.
- For other companies, the applicable rates are 7.13% and 7.21% for short-term and long-term loans in RSD, respectively, as well as a range from 4.43% to 7.10% for loans denominated in EUR, USD, and CHF, depending on maturity.
- The prescribed rates also apply to intercompany loans, with the aim of ensuring compliance with the arm’s length principle in transfer pricing.
- The application of these prescribed interest rates enables taxpayers to rely on a so-called “safe harbour”, thereby reducing the need for additional comparability analyses within transfer pricing documentation.
- The newly prescribed interest rates reflect developments in international financial markets, facilitating taxpayers’ ability to demonstrate that their related-party transactions comply with the arm’s length principle.
For additional information or consultations, the Tasić & Partners team is at your disposal.