Regulation related to tax base erosion and profit shifting (BEPS), published by OECD, is an effort to stop tax planning which uses inconsistencies between national tax laws, reduces tax base and artificially transfers profit into countries with lower tax rates, where economic activities are not performed or performed on a small scale. In order to implement BEPS, 76 countries and jurisdictions (including Serbia) signed the Multilateral Treaty. BEPS includes areas such as transfer pricing, disputes and misconducts in implementing double tax treaties, transfers of dividends, artificially avoiding the status of permanent establishment in order to reduce tax base etc.

Transfer prices, as a phenomenon which is a consequence of the global economic development and the emergence of large multinational companies, bring large risks because of conflicted interests of tax authorities and multinational companies. Tax authorities aim to increase its revenue on  one hand and on the other hand multinational companies aim to pay lower income tax. ‘’OECD Guidelines’’ is the international document, on the basis of which national tax authorities, including tax authorities of Republic of Serbia, adjust their regulation in transfer pricing. Having this fact in mind, as well as article 61a of Corporate Income Tax according to which Minister of finance regulates more closely the area of transfer pricing relying on OECD sources, changes in domestic regulation of transfer pricing can be expected after the new edition of ‘’OECD Guidelines’’, published in July 2017.