A well-planned tax policy provides the necessary incentives to promote economic growth. This chapter, along with two sub-dimensions, explores the effectiveness of tax policy and tax administration. The first sub-dimension, tax policy framework, assesses the soundness and efficaciousness of the legal framework, the tax system, and the incentives for investment in promoting steady economic growth. The second sub-dimension, tax administration, focuses on the efficiency and transparency of the tax administration organisation while also reflecting upon the tax filing and payment procedures and taxpayer services.
Western Balkans Competitiveness Outlook 2024: Serbia
5. Tax policy
Abstract
Key findings
Serbia’s overall score has marginally increased since the Competitiveness Outlook 2021, from 3.1 to 3.2 (Table 5.1). Regarding the tax policy framework, Serbia performs below the region's average, particularly due to its weaker performance in reporting tax expenditure and indirect tax policy. On the other hand, Serbia is the regional leader in tax administration, further improving its performance due to the launch of the new Transformation Programme of the Tax Administration.
Table 5.1. Serbia’s scores for tax policy
Dimension |
Sub-dimension |
2018 score |
2021 score |
2024 score |
2024 WB6 average |
---|---|---|---|---|---|
Tax policy |
4.1: Tax policy framework |
2.1 |
2.4 |
||
4.2: Tax administration |
4.2 |
3.8 |
|||
Serbia’s overall score |
2.6 |
3.1 |
3.2 |
3.1 |
The key findings are:
Serbia offers a range of tax incentives that help foster an investment-friendly environment. Moreover, in line with OECD good practices, it primarily offers cost-based, as opposed to profit-based, incentives to attract investment.
Serbia's high social security contribution (SSC) rates place a large tax burden on labour, particularly for lower-income workers. Such high rates can disincentivise work in the formal economy and strain the SSC system as Serbia’s population changes due to ageing and emigration.
The Serbian Tax Administration still does not report regularly on tax expenditures, and there are no plans to publish such a report in the future. Inaugurating regular reporting would allow the government better to assess the efficacy of tax incentives and expenditures.
Serbia remains a regional leader in tax administration due to its well-organised tax body, advanced compliance assessment and risk management procedures, and extensive taxpayer services. Performance in this area will likely continue to be strengthened through implementing the Transformation Programme of the Tax Administration (2021-25), which aims to improve business administrative processes and the quality of services for taxpayers.
While Serbia has remained engaged in the international tax community, it has yet to implement Automatic Exchange of Information (AEOI) standards, which would foster augmented tax transparency and compliance. Additionally, Serbia has not yet assessed the impacts of Global Anti-Base Erosion (GloBE) Rules on subsidiaries of multinational enterprises (MNEs) operating within its jurisdiction.
State of play and key developments
Sub-dimension 4.1: Tax policy framework
Serbia’s ratio of tax revenue to GDP is above the WB6 average. In 2021, social security contributions (SSCs) accounted for 35.6% of total tax revenues, and taxes on goods and services accounted for 40.8%. Together, these taxes make up 76.4% of total tax revenue. For comparison, SSCs in OECD member countries accounted for 26.7% of total tax revenues (OECD, 2024[1]). This difference is partly explained by the fact that Serbia collects more SSCs relative to its GDP (Table 5.2). The other part, however, is that Serbia collects less revenue from corporate and personal income taxes (CIT and PIT). In 2021, revenue from PIT made up 10.6% of total tax revenues and 4.1% of GDP, significantly below the OECD averages of 24% and 8.3%, respectively (OECD, 2024[1]).
Table 5.2. Serbia’s tax revenues composition in 2021
Tax revenues are expressed as a percentage of GDP
Corporate income tax revenues |
Personal income tax revenues |
Social Security contributions revenues |
Taxes on goods and services revenues |
Total tax revenues |
|
---|---|---|---|---|---|
Serbia |
2.5 |
4.1 |
13.7 |
15.8 |
38.6 |
WB6 |
2.1 |
1.9 |
9.9 |
14.9 |
30.4 |
OECD |
2.8 |
8.3 |
9.2 |
10.6 |
33.6 |
Note: Information on Serbia is from 2021 and information from the OECD is from 2020.
Sources: Serbia’s Ministry of Finance information provided for the Competitiveness Outlook assessment and OECD (2024[1]).
The statutory 15% corporate income tax rate is above the regional WB6 average but significantly lower than the OECD average. Like all WB6 economies, Serbia operates a worldwide tax system, in which both the domestic and foreign-sourced income of registered companies is taxed. Unless stipulated otherwise in a tax treaty, dividends distributed to non-resident corporations are subject to a 20% withholding tax. Furthermore, capital gains earned by businesses are included in the CIT base. If the capital gains are generated by a non-resident corporation within the Serbian tax jurisdiction, a 20% withholding tax is levied.
In line with OECD good practices, the CIT system relies on cost-based tax investment incentives rather than profit-based tax incentives to attract direct investment. These cost-based incentives include an enhanced CIT deduction of twice the value of qualifying investments into research and development (R&D), as well as a 30% tax credit on investments into new companies that perform qualifying innovative activities. Profit-based tax incentives include a ten-year tax holiday for investors who hire over 100 workers and invest over RSD 1 billion (EUR 8 500 000). This tax holiday is proportional to the investment made, and the number of employees must be retained throughout the tax period. Additionally, corporate income from royalties that meet certain conditions can benefit from an 80% tax deduction. Empirical evidence on the benefits of tax incentives is limited but generally supports the view that cost‑based tax incentives (tax allowances and credits) support investment with greater efficacy compared to profit-based tax incentives (tax exemptions and reduced rates) (OECD, 2022[2]).
There may also be a role for a presumptive (or simplified) tax regime targeting small businesses or vulnerable self-employed individuals. By reducing tax compliance costs and levying lower tax rates compared to the standard tax system, this regime aims to encourage business formalisation and compliance. To qualify for the flat rate taxation regime, the self-employed individual’s turnover may not exceed RSD 6 000 000 (EUR 51 000); they cannot be a registered VAT taxpayer; and they cannot engage in retail trade, hotels and restaurants, financial mediation, advertising and market research, or activities related to real estate. Common and best practices for presumptive tax regimes are outlined in Mas-Montserrat et al. (2023[3]). The self-employed with turnover above RSD 6 000 000 lose the right to flat-rate taxation and will be taxed at a 10% rate on the realised profit.
Recent international tax developments may have implications for Serbia. The Global Anti-Base Erosion (GloBE) Rules ensure large multinational enterprises pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. While countries are not required to adopt the GloBE Rules, jurisdictions that adopt them will apply an effective tax rate test. Using a common tax base and a common definition of covered taxes, the test will determine whether an MNE is subject to an effective tax rate of at least the agreed minimum rate of 15% in any jurisdiction where it operates (OECD, 2022[4]). For Serbia, that means that in-scope Ultimate Parent Entities of MNE Groups – that have their headquarters in a jurisdiction that has implemented the GloBE Rules and that operates a subsidiary (or Constituent Entity) in Serbia – may be subject to a top-up tax in the residence jurisdiction, if the profits earned in the subsidiary are taxed at an effective rate below 15%. Although Serbia has a 15% CIT rate, investment tax incentives may lower the effective tax rate of some businesses.
Serbia has continued to make strides in terms of its engagement in the international tax frameworks, as it is a member of the Inclusive Framework on BEPS (base erosion and profit shifting) and has been implementing Country-by-Country Reporting requirements. Additionally, in 2018 it joined the OECD Global Forum, and in 2019 it signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. However, Serbia does not yet participate in the exchange of tax information under the OECD Automatic Exchange of Information (AEOI) standard. Doing so would allow the economy to increase compliance and more efficiently tax capital income at the individual level (OECD, 2017[5]).
Although the personal income tax (PIT) in Serbia has a progressive rate for a higher tax bracket, the vast majority of wage earners fall within the same bracket. Serbia levies a rate of 10% on wage income up to six times the average annual salary and then 15% for income above that threshold. The top PIT rate is low by international standards and furthermore is applied only to a very narrow base. For comparison, the average top PIT rate in OECD member countries in 2021 was 42.5%. The standard annual allowance is RSD 260 544 in 2024 (EUR 2 225) and has been increased regularly over the past three years. Dividend income and capital gains are taxed at 15%, and all other types of capital income, such as rental or royalty income, are taxed at 20%. Income from self-employment is taxed at a rate of 10%, regardless of the amount of income. In addition to the PIT, Serbia imposes an annual tax on individuals whose yearly income exceeds three times the average annual wage per employee in the economy, with a non-taxable threshold set at RSD 4 269 564 (EUR 36 463). Decreased for certain deductions, this annual tax follows a progressive tax rate structure: 10% is applied to income up to six times the average annual wage, while income exceeding this threshold is taxed at a rate of 15%.
Serbia has one of the highest social security contribution (SSC) rates in the Western Balkans region. The total rate is 35.05%, which is split into 15.15% for the employer and 19.9% for the employee. The self-employed are required to pay the combined rate of 35.05% of their income. It is worth mentioning that Serbia has been pursuing a strategy of decreasing SSC, with the contribution rate for mandatory pension and disability insurance being reduced from 25.5% in 2021 to 24% in 2023. These remaining high SSC rates may result in a significant tax burden on low-paid and low-skilled workers, reducing incentives to work and contributing to the informal sector's size. This is worsened by the fact that there is a minimum contribution of 35% of the average wage. That said, informal employment has regularly declined since 2018, reaching 13% in 2022 and 6.9% when excluding the agricultural sector (Statistics Office of the Republic of Serbia, 2023[6]).
This reliance on SSCs is a particularly salient issue due to population ageing and emigration trends. Between 2012 and 2022, the share of the population 65 years or over grew by four percentage points (compared to the EU average of 3.1 percentage points) (Eurostat, 2023[7]). With this recent growth, Serbia has one of the highest proportions of older people in the region. Given the likely impacts of these structural changes on the economy, Serbia has already begun preparing an analysis of the effect of population ageing on the sustainability of its pension system in the mid- and long term. The Tax Administration intends to regularise the analysis through a 3- or 5-year time frame.
Modelling and forecasting are a cornerstone of strong tax policy analysis. The Ministry of Finance uses macroeconomic modelling to project future revenues for all major types of taxes. This model is regularly assessed to ensure its forecasts’ reliability, and it has been adjusted accordingly. However, Serbia has not yet implemented any micro-simulation models to analyse the revenue impact of alternative tax regimes. Consequently, the economy might consider developing micro-simulation models that utilise tax data to gauge the costs and distributional impacts of potential policies.
Regarding the design and functioning of the value added tax (VAT) system, Serbia’s standard VAT rate is 20%, which is similar to the WB6 and OECD average. The VAT base, however, is fairly narrow due to a relatively high VAT threshold (RSD 8 000 000, or EUR 68 000) and a reduced rate of 10% that applies to a wide range of goods and services. Moreover, to strengthen VAT compliance, Serbia has implemented several measures, such as regularly calling or visiting new companies to explain the regulations or offering online presentations via the Tax Administration. However, the biggest change has been the implementation of electronic invoicing, which has had a significant impact on VAT collection in Serbia (Box 5.1).
Box 5.1. Serbia’s Sistem e-Faktura electronic invoicing system
In Serbia, a transformative shift in the VAT system occurred at the start of 2023, when the Serbian Government passed a new regulation mandating the use of electronic invoices (e-invoices) in business-to-business transactions for both domestic and foreign companies operating within the economy. This regulation was the last piece in a comprehensive approach that encompassed various transaction types (including business-to-government and government-to-business in addition to business-to-business).
Further reinforcing this commitment to modernising VAT collection processes, the Law on Electronic Invoicing underwent significant amendments in November 2023. These changes, effective 1 January 2024, introduced a crucial alteration to the VAT law. Notably, taxpayers are now obligated to electronically record the VAT calculated in the preceding supply phase. Additionally, the deadline for this electronic recording was shortened from 15 to 10 days.
The implementation of these regulatory changes was supported by the launch of a new e-invoicing system called Sistem e-Faktura (SeF) by the Ministry of Finance. SeF was designed to facilitate the sending, receipt, processing and storage of electronic invoices, improving the efficiency and transparency of these processes. Entities can either create and submit e-invoices manually through the portal or connect their Enterprise Resource Planning (ERP) systems to the national system.
Source: Ministry of Finance (2024[8]).
In terms of digital taxation, Serbia levies a VAT on cross-border digital services, and its VAT rules make reference to the place of residence of the consumer, largely following the destination principle outlined in the International VAT/GST (goods and services tax) Guidelines. However, Serbia has yet to formally implement the Guidelines, while its Law on Value Added Tax remains only partially harmonised with EU regulations.
With respect to health taxes, Serbia levies a specific excise tax on alcohol products and both an ad valorem and a specific excise tax on tobacco products, which is a common approach among OECD countries. Combining specific and ad valorem taxes for tobacco products is an effective strategy for discouraging consumption of, or maximising revenue from, both high- and low-value products (OECD, 2020[9]). Aligned with the EU Directive on Tobacco Taxation, there is also a minimum specific excise tax per kilogramme of tobacco (World Bank Group, 2018[10]). The total tax burden on cigarettes in Serbia is 76.4% of the retail price, which is in line with the 75% minimum recommended by the World Health Organisation (WHO).
In contrast to the relatively well-developed health taxes, environmentally related taxes in Serbia are much more limited. The only instance of these taxes is the excise duty levied on gasoline and diesel fuel. As such, there is substantial scope to further increase and broaden environmentally related taxes, such as by introducing a carbon tax. Such efforts could help Serbia align itself with the objectives outlined in its national emission reduction plan.1 Moreover, the Serbian Government has yet to assess the impact of the EU Carbon Border Adjustment Mechanism (CBAM).2 Not only is alignment with EU climate goals important for Serbia’s accession ambitions, but CBAM’s introduction may also impact several of Serbia’s emission-intensive sectors.
Unlike other WB6 economies, Serbia still does not conduct tax expenditure reporting on a regular basis. Doing so would allow it to monitor the use and effectiveness of tax incentives and tax expenditures along with the tax revenue forgone. A regular tax expenditure report should identify, measure, and report on the cost of tax expenditures in a way that enables their cost to be compared with direct spending programmes. Policy makers can then conduct cost-benefit analysis to evaluate whether specific tax incentives are meeting their stated objectives and, if not, whether they should be abolished or replaced.
Sub-dimension 4.2: Tax administration
Following the OECD's good practices on tax administrations’ functions and organisation, the Serbian Tax Administration is a unified body that oversees all taxes and core administrative functions. It is responsible for collecting all taxes except those on real estate, which fall under the jurisdiction of local governments. Additionally, the State Audit Institution and an independent body that reports to the Serbian National Assembly regularly assess the Tax Administration's functioning. This body has also worked on improving the auditing and tax collecting skills of its employees through annual training programmes.
The Serbian administration employs a risk-based method for compliance assessment. The Tax Administration uses a comprehensive set of risk criteria to identify taxpayers for audits each month. Research from the OECD indicates that this risk-based selection is critical for the efficiency of compliance programmes, as they enable administrations to allocate resources effectively (OECD, 2020[11]).
To further bolster the independence and transparency of the Tax Administration, the government accepted the Transformation Programme of the Tax Administration for the period 2021-25. The new programme aims to improve the administrative process for businesses and citizens and the quality of taxpayer services. While the Tax Administration has a distinct legal status and its own operating budget, it has yet to establish an independent management board.
In terms of tax filing and payment procedures, Serbia requires that tax returns be filed electronically for all entrepreneurs and companies. Moreover, the PIT return also must be filed on line. Tax returns for CIT and income taxes levied on self-employment business income are submitted once a year. Serbia’s Tax Administration has developed a system that validates the data reported in tax returns and can correct these returns as needed.
Taxpayer services include online information access, e-filing and online tax payments, and virtual and in-person services. Information requests are answered within three working days when posed via phone and within seven days when posed via letter. Several mechanisms are used to measure taxpayers’ satisfaction, including surveys available in the Tax Administration’s portal, using the contact centre voice machine’s recordings and an independent survey conducted by the marketing agency IPSOS.
Overview of implementation of Competitiveness Outlook 2021 recommendations
Serbia’s progress in implementing past OECD Recommendations has been mixed. In some areas, such as strengthening the tax administration’s functioning, the economy has made strong advances since Competitiveness Outlook 2021. Conversely, its progress has stalled or been limited in most domains, including developing micro-simulation models, or expanding the VAT base. Table 5.3 shows the economy’s progress in implementing past recommendations for tax policy.
Table 5.3. Serbia’s progress on past recommendations for tax policy
Competitiveness Outlook 2021 recommendations |
Progress status |
Level of progress |
---|---|---|
Strengthen support to the economy and facilitate the economic recovery |
Most tax support measures have been phased out, and some have been made permanent. |
Strong |
Diversify the tax mix by strengthening the role of corporate and personal income taxes |
There have been few to no developments in this area, as the VAT base is still narrow with a high registration threshold. |
Limited |
Instigate a regular report on tax expenditures |
No policy actions have been taken. |
None |
Weigh the advantages and disadvantages of the differentiated taxation of capital and labour income |
There is no indication that such an assessment was conducted. |
None |
Broaden the VAT base by reducing the list of goods and services taxed at the reduced rate and, possibly, by lowering the VAT registration threshold |
There have been few to no developments in this area. |
None |
Strengthen the design and progressivity of the PIT |
PIT is progressive, but no significant developments have been implemented since the Competitiveness Outlook 2021. |
None |
Rebalance the taxation of labour income away from high employer and employee SSCs |
No policy actions have been taken. |
None |
Develop an action plan in case consensus is found on a possible global minimum tax among members of the OECD/G20 Inclusive Framework on BEPS |
There is no indication that such an assessment is taking place and/or has resulted in policy actions. |
None |
Implement micro-simulation models to analyse the impact of tax system changes |
Serbia has limited tax revenue forecasting models but has made limited progress in developing and using micro-simulation models. |
Limited |
Continue to strengthen the functioning of the tax administration |
In 2021, the government accepted the Transformation Programme of the Tax Administration for the period 2021-25. The new programme aims to improve the administrative process for businesses and citizens, and the quality of taxpayer services. |
Moderate |
Continue to engage with the international tax community and implement international best practice |
Serbia continues to engage in the international tax community. Serbia is a member of the Inclusive Framework on BEPS and has made continued progress in implementing country-by-country (CbC) requirements. |
Moderate |
Carry out a cost-benefit analysis on the merits of the worldwide taxation system for resident corporations |
There is no indication that such an assessment has taken place and/or resulted in policy changes. |
None |
Foster regional co-operation and co-ordination on common tax issues |
There is regional co-operation through bilateral agreements, but few developments have occurred in recent years. |
Limited |
The way forward for tax policy
Considering the implementation level of the previous recommendations, there are still areas in which Serbia could enhance the tax policy framework and further improve the functioning of the tax administration. As such, policy makers may wish to:
Assess the impact of GloBE Rules on subsidiaries of multinational enterprises within Serbia. Depending on the outcome of this assessment, Serbia may want to revise some of its tax incentives and corporate income tax rates. In particular, profit-based tax incentives, such as rate cuts and exemptions, are more likely to be impacted by the GloBE Rules and evidence of their effectiveness is limited. Additionally, to avoid forgoing revenue in the short term, Serbia may also wish to consider introducing a qualified domestic minimum top-up tax (QDMTT) that would increase the effective tax rate of relevant subsidiaries to 15%.
Consider reducing SSC rates and shifting the tax burden onto a more progressive PIT system, including personal capital income taxes, health taxes, and environmentally related taxes. Shifting the tax burden from SSCs onto a more progressive PIT system could improve both the equity and efficiency of the tax system. On equity, increasing the number of PIT brackets and introducing a higher top PIT rate would make the tax system more redistributive and raise revenues. Meanwhile, reduced SSC rates and low-bottom PIT rates decrease barriers to formal employment.
Assess the potential impact of demographic changes on revenue and the functioning of the SSC system. Developing a plan to make the system’s public finances more resilient to population ageing and emigration trends is crucial.
Consider reforming the presumptive tax regime targeting small businesses or vulnerable self-employed individuals. The current regime only applies to self-employed individuals. Policy makers may wish to analyse whether there is scope for other presumptive tax regimes aimed at small businesses to induce formalisation (Box 5.2).
Box 5.2. Presumptive tax regimes
Presumptive tax regimes target taxpayers that are “hard-to-tax” businesses (i.e. the self-employed, unincorporated businesses, micro and small enterprises, farmers). Hard-to-tax taxpayers usually have low incomes, do not register voluntarily with the tax administration, do not keep complete books, do not file tax returns and use cash payments, all of which make it difficult for the Tax Administration to monitor them and ensure compliance (Thuronyi, 2004[12]; Rajaraman, 1995[13]). Given the high levels of informality associated with many low- and middle-income countries, presumptive tax regimes could form an important component of countries’ tax systems if well designed and enforced.
A presumptive tax regime levies tax on a presumed tax base that is intended to approximate net taxable income by indirect means (Iordachi and Tirlea, 2016[14]; Thuronyi, 2004[12]). These regimes can be particularly relevant where actual taxable income is difficult to assess accurately (Logue and Vettori, 2011[15]). This is the case, for instance, where businesses do not keep complete books or where cash payments are prevalent.
Presumptive tax regimes aim at encouraging tax compliance by reducing tax compliance costs and by levying lower tax rates compared to the standard tax system (Loeprick, 2009[16]; Balestrino and Galmarini, 2005[17]). Tax compliance costs are associated with recording transactions, maintaining accounting records and financial statements, calculating tax liabilities, and following tax payment procedures (OECD, 2009). Small taxpayers with generally lower profits than larger ones tend to be disproportionately impacted by fixed compliance costs (OECD, 2009[18]; 2015[19]; ILO, 2021[20]). By reducing the administrative burden (e.g. with simplified bookkeeping rules), presumptive tax regimes contribute to reducing informality and broadening the tax base (Engelschalk, 2004[21]).
For the Tax Administration, presumptive tax regimes reduce the administrative costs of monitoring hard-to-tax businesses and ensuring their compliance. Regular assessment of their books can be difficult, especially where non-compliance is extensive and administrative resources are limited (Bucci, 2020[22]). While these regimes allow the tax administration to easily determine the tax liabilities of many small taxpayers (Engelschalk, 2007[23]), they do not prevent the administration from conducting regular and thorough controls of at-risk businesses (Bulutoglu, 1995[24]).
Presumptive tax regimes are present in many tax systems and differ widely in their design dimensions (e.g. the target group, the eligibility criteria, the presumption of the tax base and the tax liability, etc.) (Bucci, 2020[22]). These multi-dimensional differences complicate cross-country comparability and, thus, the extraction of solid conclusions for an optimal design.
In a working paper, the OECD discusses an analytical framework that allows for the systematic characterisation of country-specific presumptive tax regimes and the identification of their differences and commonalities. This benchmarking exercise would allow for an examination of each regime's strengths and weaknesses so that countries can identify opportunities to improve their presumptive regimes. The analytical framework can also help identify some of the key design questions worthy of receiving closer analytical attention in the future.
By discussing design features of presumptive regimes and identifying their issues, the working paper also lists a series of best practices for their design and administration. These best practices are accompanied by potential challenges the tax administration might face in their management, and desirable conditions for their implementation.
Source: Mas Montserrat et al. (2023[3]).
Analyse the potential benefits of broadening the VAT base. By lowering the VAT registration threshold and reducing the range of goods and services to which a reduced VAT rate applies, broadening the VAT base improves the neutrality of the tax, lowers distortions, and may raise revenues.
Start regularly reporting tax expenditures to monitor their use and increase transparency. Such analysis will also allow policy makers to conduct cost-benefit analyses to review their effectiveness.
References
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Notes
← 1. National Plan to reduce emissions of major pollutants originating from large old combustion plants, Official Gazette of RS, no. 10, 6 February 2020.
← 2. The EU CBAM is the policy instrument designed to reduce the likelihood of carbon leakage by instituting a carbon price on imported goods. This tool reflects EU commitments to reducing its greenhouse gas emissions under the “Fit for 55” package while still ensuring a level playing field between EU and non-EU businesses. The CBAM’s transitional period, which started on 1 October 2023 and continues until the end of 2025, exclusively involves reporting obligations; however, from 1 January 2025, carbon pricing will also be implemented.