Corporate income tax

The main goals of our training are solving practical problems and situations that clients and managers face, as well as training for independently performing complex tasks in the field of income tax, compiling a tax balance in full compliance with the law, compiling a tax return and all supporting attachments.

Program content
  • The latest changes in tax regulations in the field of income tax
  • Taxable profit as a starting point - definition of income and expenses
  • Risks of misstatement and recognition of income and expenses
  • Documentation of costs - Article 7a of the Law on Corporate Income Tax
  • Expenses not incurred for the purpose of conducting business activities
  • Impairment and write-off treatment of receivables - examples from practice
  • Calculation of tax depreciation / procurement of funds from related parties - examples from practice
  • Impairment and write-off treatment of receivables - examples from practice
  • Other expenditure adjustments
  • Alignment of income
  • Experiences in tax controls and tax practice
  • Possibilities for tax optimization
Benefits for participants
  • Introduction to new regulations and opinions of the Ministry of Finance
  • Training for independent preparation and control of tax balance, tax return and attachments to the tax return
  • Better understanding of corporate tax laws based on examples and tax practices
  • Solving practical issues through discussion with the consulting team

Avoidance of double taxation

Program content
  • Double Taxation Treaties (DTTs) - agreements in force, new agreements signed and initialed, agreements being negotiated and announcement of new negotiations
  • Multilateral Convention and its impact on existing and new DTTs
  • Current status of amended DTTs in accordance with the Multilateral Convention
  • Determining resident status in accordance with the DTTs
  • Copyright vs services in line with the withholding tax aspect
  • Will the implementation of the multilateral convention affect the change of domestic legislation
Benefits for participants
  • Introduction to the new Double Taxation Treaties and the opinions of the Ministry of Finance
  • Considering business optimization opportunities using the benefits of DTTs
  • Proactive approach when making business plans for the next period
  • Identification of potential risks from the aspect of withholding tax
  • Resolving doubts in the practical application of DTTs

Tax challenges in the digital economy

The digital economy is a great challenge for the existing tax regulations, which need to be adapted to the new business concept, so as not to hinder the further development of digital business.
The key challenges that the digital economy brings to tax regulation are:

  • Constantly reducing the company's need for physical presence to conduct its business activities
  • The ability of companies to generate and process an increasing amount of data
  • Development of digital products and new ways of distributing services
  • The impact of digital commerce on VAT collection

Most of the measures of the new Law on Income Tax refer to tax relief for companies that have intellectual property registered in Serbia, as well as companies that are engaged in research and development in Serbia or perform or invest in innovation activities.

Program content
  • Tax challenges in the digital economy and the latest regulatory changes
  • Tax benefits for IT companies: tax credit on investments in start-ups, tax incentives for investments in research and development, tax deducted from revenues from the sale of licenses
  • Tax treatment of the acquisition of licenses from the point of view of withholding tax and VAT
  • Flat-rate taxation - risks and opportunities - how to ensure safer business from the aspect of tax risks
  • Possibilities for tax optimization
  • Related party business - transfer prices
Benefits for participants
  • Understanding the tax environment in digital business
  • Opportunities to independently identify risks from the tax aspect and opportunities for tax optimization
  • Introduction to new regulations and opinions of the Ministry of Finance
  • Solving practical issues through discussion with the consulting team

How to prepare for tax control?

Program content
  • Will the reform of the tax administration lead to substantial changes in the relationship with taxpayers?
  • Rights and obligations of taxpayers in the tax control procedure
  • Advantages and risks of initiating tax control by taxpayers
  • Do the company and the tax administration or the employees and the tax inspector participate in the tax control?
  • Should the tax advisor be called in to file an appeal against the decision or when you receive a control order?
Benefits for participants
  • Introduction to the specifics of the tax procedure of tax control, rights and obligations of the taxpayer
  • Introduction to the announced changes in the tax administration
  • Understanding the specifics of the requirements of tax inspectors based on numerous experiences from controls
  • Internal acts as a risk mitigation mechanism
  • Possibilities for independent assessment of tax risks
  • Solving practical issues through discussion with the consulting team
  • Perception of tax control as a relationship between people

Personal income tax

Personal income ta together with contributions to mandatory social insurance makes up about 37% of the total budget revenues of the Republic of Serbia. The payment of taxes and contributions is a very sensitive issue due to the fact that employees whose exercise of rights depends on the stated payments are interested in the same. Also, increasing the tax base by not recognizing certain expenses in the tax balance, in most cases is not an argument that these expenses are not taxed by personal income tax. Finally, the personal income tax is a withholding tax, so any non-calculation and non-payment of taxes is considered a separate tax offense. Therefore, it is not surprising that the personal income tax is in the focus of the tax administration when it comes to tax controls and that a significant number of controls of income tax and VAT are extended to control the calculation and payment of personal income tax.

Program content
  • Income taxation in Serbia and other countries - how to optimize income taxation?
  • Can directors and board members be hired free of charge?
  • Will the flat-rate taxation be changed and in what way?
  • Taxation of non-residents earning income in Serbia and residents earning income abroad
  • Non-recognition of expenditures in the tax balance and taxation of personal income tax
Benefits for participants
  • Introduction to the expected changes in the regulations in the taxation of personal income tax
  • Identify the potential risks to which your company is exposed from the aspect of personal income tax
  • Considering the possibilities for income tax optimization in your company
  • Resolving current doubts through the exchange of experiences with consultants and colleagues from other companies

Value added tax

Interest in value added tax (VAT) is on the rise, given the conflicting interests of multinational companies that want to manage their cash flows by optimizing VAT, and the governments of nation states for which VAT is a significant source of revenue. (For example, about 50% of tax revenues are generated by the Government of the Republic of Serbia by collecting VAT).

In our opinion, the best possible advice regarding value added tax is given if the result is the formation of a structure (supply chain) that easily fits into the company's environment - both nationally and internationally.

Program content
  • VAT regulations in Serbia in relation to the legislation in the European Union - key differences
  • Current values in the field of value added tax
  • Expected changes in VAT regulations in the coming period
  • Application of VAT regulations that have recently entered into force
  • Tax and court practice
  • Open issues on which the official position of the Tax Administration and the Ministry of Finance has not been taken
Benefits for participants
  • Review of the current state of VAT regulations in Serbia and the EU
  • Timely preparation for changes in VAT regulations in the coming period
  • Elimination of doubts in the practical application of existing VAT regulations
  • Get acquainted with open issues that can affect your business

BEPS (Base Erosion and Profit Shifting)

The BEPS regulation, published by the OECD, is an attempt to prevent tax planning that exploits inconsistencies in countries' tax laws, reduces the tax base and artificially shifts profits to countries with lower tax rates, where economic activity does not take place at all or on a small scale. In order to implement the BEPS in Paris, in June 2017, 76 countries and jurisdictions (including Serbia) signed the Multilateral Agreement, which is the basis for amending the treaties on avoiding double taxation. Some of the BEPS actions that will have an impact on our laws are: Preventing artificial avoidance of the status of a permanent business unit, preventing the reduction of the tax base through debt, preventing inadequate use of contractual benefits, tax challenges in the digital economy, improving dispute resolution mechanisms.

Program content
  • Overview of BEPS actions: what has already been implemented in Serbia, and what will be implemented soon?
  • Implementation of the Multilateral Agreement: Amendments to the Agreement on Avoidance of Double Taxation
  • Changing conditions for reduced capitalization
  • Change of regulations on permanent business unit
  • Change in transfer pricing regulations
  • Taxation in the digital environment
Benefits for participants
  • Reference to BEPS provisions in tax judgment (principle of fact)
  • Understanding of completed and expected changes in Serbian tax regulations
  • Understanding the impact of BEPS on the business of your company / group
  • Understanding the impact of globalization and new technologies on tax regulation

Transfer prices

The highly dynamic global business environment, as well as the growing pressure from tax administrations to generate tax revenues from all sources, puts transfer pricing at the top of today’s tax and financial issues. Therefore, we believe that it is very important to dedicate ourselves to the tax implications in intercompany transactions and to acquire key knowledge.

Program content

The concept of transfer pricing and the legal framework

  • Regulations governing transfer prices (direct and indirect sources of law)
  • OECD Transfer Pricing Guidelines
  • Setting “arm's length principles”
  • Identification of related parties and definition of transactions with those entities - examples through different ownership structures

Value chain in intercompany transactions

  • The relevance of the value chain in the overall transaction from the aspect of profit distribution
  • Functional analysis: Significance of the degree of activities performed, use of assets and risks taken

Related party transactions

  • Basic transactions: Sale and purchase of materials for production, goods and finished products, transactions with real estate and equipment
  • Intercompany services
  • Transfer of intangible assets
  • Comparability analysis: comparability factors, PRACTICAL EXAMPLES
  • "Arm's length" interest
  • 4 ways to reduce the correction due to income and expenses on the basis of intercompany loans
  • The amount of interest in terms of double taxation agreements

Transfer pricing methods

  • Analysis of all transfer pricing methods and application criteria EXAMPLES FROM PRACTICE
  • The way of deciding on the choice of a specific method for a specific transaction
  • Practical application of the method
  • Use of databases: Criteria in the database, qualitative analysis
  • Selection of comparable companies, calculation of profit level indicators

Conclusion on the necessity of correcting the tax base

  • Calculation of the value of transactions on the principle of " arm's length"
  • Calculation of the final correction / Reduction of the correction by punching: Various examples
Benefits for participants
  • Training for independent participation in the analysis and drawing conclusions on the compliance of intercompany transactions with the law
  • Expert conclusions regarding intercompany transactions for more than 30 cases
  • Obtaining the entire material, including models for functional analysis, correction calculations, interest
  • Solving practical issues through discussion with the consulting team
  • Continuous support on all issues by our consulting team, which has done over 400 studies on transfer pricing in a total of 500 engagements in large local and multinational systems

IFRS 15 and IFRS16 - Tax Aspect

Program content
  • Reasons for adopting and objectives of the new standards - IFRS 15 Contracts with customers and IFRS 16 - Lease
  • Beginning of application in Serbia
  • A brief overview of the most significant changes that the new standards bring in relation to the previous ones
  • What will the application of the new standards change in the daily business of economic entities?
  • How the new standards affect the structure and results of financial statements
  • What are the tax implications of applying the new standards
Benefits for participants
  • Timely preparation for the application of new standards
  • Introduction to the most significant changes in relation to the current situation
  • Considering the impact of new standards on everyday business
  • Considering the tax effects of the application of new standards