Pursuant to Article 61, paragraph 3 of the Corporate Income Tax Law (“Official Gazette of the RS”, Nos.25/01, 80/02, 80/02 – state law, 43/03, 84/04, 18/10, 101/11, 119/12, 47/13, 108/13, 68/14 – state law, 142/14, 91/15 – authentic interpretation, 112/15, 113/17, 95/18, 86/19, 153/20, 118/21 and 94/24), the Minister of Finance issued the Rulebook on Interest rates deemed to be in accordance with the “arm’s length” principle for 2026 (hereinafter: the “Rulebook”), which was published in the Official Gazette of the RS No. 36/2026 on April 24, 2026 and entered into force on May 02, 2026. This Rulebook prescribes the interest rates which, in accordance with the “arm’s length” principle, shall be applied in 2026 to loans and credits between related parties.The prescribed interest rates apply for the purposes of determining corporate income tax for 2026 and may also be applied for the purposes of calculating withholding tax in the case of payment of interest income to related non-resident legal entities.
Below is an overview of the prescribed interest rates for 2026.:
For banks and financial leasing providers:
▪ 4.40% on short-term loans in RSD;
▪ 0.33% on long-term loans in RSD;
▪ 4.87% on loans in EUR and RSD loans indexed to EUR;
▪ 4.98% on loans in USD and RSD loans indexed to USD;
▪ 3.05% on loans in CHF and RSD loans indexed to CHF;
▪ 4.12% on loans in SEK and RSD loans indexed to SEK;
▪ 1.50% on loans in GBP and RSD loans indexed to GBP;
▪ 10.73% on loans in RUB and RSD loans indexed to RUB.
For other companies:
▪ 7.13% on short-term loans in RSD;
▪ 7.21% on long-term loans in RSD;
▪ 4.75% on short-term loans in EUR and RSD loans indexed to EUR;
▪ 5.42% on long-term loans in EUR and RSD loans indexed to EUR;
▪ 7.10% on long-term loans in CHF and RSD loans indexed to CHF;
▪ 4.43% on long-term loans in USD and RSD loans indexed to USD.