Amendments to the RS Corporate Income Tax Law and transfer pricing
The Law Amending and Supplementing the Law on Corporate Income Tax was published in the Official Gazette of Republika Srpska, No. 114/2025 of 29 December 2025. One of the more significant amendments concerns transfer pricing, namely the obligation of businesses to hold and submit transfer pricing documentation.
Very soon after these amendments were published, transfer pricing became one of the “hot” topics among business owners and accountants:
- what transfer pricing is,
- who is subject to the obligation,
- and what the consequences of non-compliance with the Law are.
The obligation to hold a transfer pricing study
It is important to stress that the obligation to hold a transfer pricing study is not new. Taxpayers with related-party transactions were already required to hold adequate documentation (a transfer pricing Study/Report) at the time of filing the tax balance and to submit it within 30 days of a request from the tax authority.
The previous legal framework also contained penalty provisions in the form of fines for not holding transfer pricing documentation and for failing to submit it within 30 days of a request from the tax authority, ranging from BAM 20,000 to BAM 60,000 for a legal entity and from BAM 5,000 to BAM 15,000 for the responsible person in the legal entity.
New obligation to submit transfer pricing documentation
What is genuinely new, however, is the obligation to submit the documentation (the transfer pricing Study/Report) proactively, without a specific request from the tax authority. The Study/Report must correspond to the data in the tax return for the previous year, which is filed no later than 31 March of the current year for the previous tax year.
A 9-month deadline for submitting the transfer pricing report
Under the new rules, transfer pricing documentation must be submitted to the Tax Administration within nine months of the end of the tax year, without a specific request from the Tax Administration.
A BAM 50,000 threshold for related-party transactions
A materiality threshold of BAM 50,000 has also been introduced: the obligation arises if the total value of related-party transactions (including credits and loans) exceeds this amount during the tax year.
What do the amendments mean for businesses dealing with related parties?
If your business:
- has transactions with a related legal entity or individual,
- grants or receives loans between related legal entities and individuals,
- sells goods or services within the group,
you are very likely required to have a transfer pricing study.
