Tax Law

Other areas of expertise:

Tax law is one of the most important aspects of doing business for any company or individual. Timely and accurate fulfillment of tax obligations is not only a legal duty but also the foundation for preserving reputation, stability, and long-term sustainability.

In practice, even the smallest error can lead to significant financial consequences, while a well-designed tax strategy can substantially reduce liabilities and open space for new investments.

With increasingly complex domestic and international regulations, as well as constant legislative changes, effective tax planning and compliance have become essential for both businesses and individuals.

Our tax law team combines years of experience, practical knowledge, and a strategic approach, providing legal security and optimization of tax obligations in full compliance with applicable laws.

Why Zunic Law for Tax Law?

Experience and expertise – extensive track record with corporations, SMEs, entrepreneurs, and individuals.
End-to-end support – from planning and compliance, through use of tax incentives, to representation before the Tax Administration and courts.
International perspective – expertise in domestic and international tax law, especially in cross-border transactions.
Personalized strategies – recommendations and advice tailored to the client’s business model and long-term goals.
Prevention and optimization – the goal is not only to reach compliance, but also to identify the best solutions for minimizing tax burdens.

Our Approach: Stability and Growth through Smart Tax Planning

Our approach combines legal certainty with business efficiency. Each client receives a detailed analysis of tax risks and opportunities, along with a clear optimization plan. We focus on prevention by addressing irregularities before they cause consequences and maximizing the use of tax benefits.

We apply modern tools and cooperate with financial and accounting experts to provide clients with comprehensive and sustainable solutions.

Key Tax Law Practice Areas

For Corporations and SMEs

Tax compliance and optimization
Employment-related tax incentives
R&D tax incentives
Taxation of intellectual property

For Entrepreneurs

Income tax compliance
VAT and business taxation
Independence test

For Individuals

Tax residency and international taxation of natural persons
Capital gains and property tax
Personal income tax and withholding tax
Digital assets taxation

Below are details by area, with a focus on concrete results we deliver.

Tax Services for Corporations and SMEs

1. Tax compliance and optimization

Corporate income tax compliance – detailed review of accounting policies, tax returns, and supporting documentation (calculations, contracts) to eliminate discrepancies before audits. Preparation of internal compliance checklists and corrective measures.
Tax optimization – lawful planning to reduce tax burdens: proper time optimization of income and expenses, use of depreciation and value adjustments, utilization of credits and incentives, and adequate drafting of commercial terms.
Risk assessment and management – mapping “red flags” (e.g., undocumented expenses, representation costs, late payment interest), quantifying effects, and proposing remediation plans.
Tax due diligence (pre-transaction) – reviewing the tax position of target companies before acquisitions/reorganizations (open issues, potential liabilities, and concerns).
Operational support – preparing forms, records, and explanations for the Tax Administration; delivering training for finance/accounting teams to maintain compliance.

Result: business security, reduced unnecessary costs, and predictable tax obligations.

2. Employment-related tax incentives

Eligibility screening – verifying if terms are met for specific incentives (in case of: new hires, young employees, returnees, shortage occupations), including time limits and overlaps with other benefits.
Documentation and procedures – preparing confirmations, statements, and internal acts; setting up records required by authorities (e.g., headcount, payroll tracking).
Compensation models – structuring salaries and benefits (bonus schemes, perks) to maximize incentives without reclassification risk.
Monitoring retention – ensuring employee retention obligations are met; identifying risks of retroactive loss of incentives.

Result: lower labor costs and sustainable use of state incentives without risk of clawback.

3. R&D tax incentives

Identifying qualifying activities – distinguishing R&D from routine operations, defining scope and objectives under regulations.
Expense tracking – setting granular records (materials, labor, contractors, prototypes) to ensure recognition.
R&D files – preparing narrative and financial justifications, internal acts, and technical documentation for approvals and audits.
Calculation and utilization of tax incentives for R&D – choosing optimal use (deduction, credit), aligning with annual CIT filing, and planning cycles.

Result: boosted innovation with measurable reduction of effective tax burden.

4. IP taxation

Structuring IP ownership and use – advising on agreements and internal acts for transfers/licensing to achieve tax efficiency.
Income and expenses from IP – defining treatment of royalties, license fees, and R&D/maintenance costs in line with law.
Documentation and calculations – preparing contracts, reports, and explanations required during audits.
Local compliance – addressing specific domestic requirements (e.g., source of income, place of taxation, recordkeeping).

Result: maximized IP value with clear, defensible tax treatment.

Tax Services for Entrepreneurs

1. Income tax compliance

Selecting tax regime – helping select business form (entrepreneur, lump-sum, LLC) and tax regime based on revenues, expenses, and growth plans.
Filings and prepayments – setting up obligation calendars, preparing returns, and introducing internal accuracy checks.
Deductible expenses – setting rules for documenting and classifying costs (travel, representation, equipment, rent) for recognition.
Mid-year changes – advising on thresholds, activity changes, or regime shifts to minimize disruption.

Result: orderly compliance and optimized effective income tax.

2. VAT and business taxation

Registration and thresholds – assessing obligation or benefits of VAT registration; preparing applications and records.
Input VAT deduction – introducing controls on e-invoices, postings, and deduction conditions; preventing cumulative errors.
Special regimes – advising on exemptions (exports, specific services), place of supply, and advance payment treatment.
Internal processes – aligning invoicing, contracts, and logistics with VAT rules.

Result: VAT compliance and reduced risk of penalties/interest.

3. Independence test

Criteria analysis – assessing client–contractor relationship under statutory indicators (dependence, control, risk, equipment).
Contract clauses – recommending changes to ensure independence and avoid reclassification as employment.
Corrective measures – operational adjustments (multiple clients, own equipment, responsibility for results).
Evidence documentation – preparing proof and internal policies for audits.

Result: minimized risk of retroactive taxes, contributions, and fines.

Tax Services for Individuals

1. Residency status and taxation

Determining residency – assessing residency status under domestic law and tax treaties to prevent dual residency conflicts.
Relocation planning – pre-move advice on income, property, and capital gains taxes, and reporting duties.
Reporting worldwide income – setting up records, deadlines, and foreign certificates (e.g., proof of tax paid) to avoid double taxation.
Documentation and deadlines – preparing forms, statements, and supporting documents for filing.

Result: optimized overall tax burden and compliant international position.

2. Capital gains tax

Scope and identification – clarifying when capital gains arise (real estate, shares, instruments) and applicable exemptions.
Cost basis records – tracking acquisition price, investments, and transaction costs; adjusting for FX differences where relevant.
Use of losses – advising on offset and carryforward options under relevant regulations.
Deadlines and forms – preparing filings and calculations, minimizing audit risks.

Result: accurate calculations and rational reduction of capital gains liabilities.

3. Withholding tax

Payer and recipient obligations – explaining when withholding applies (interest, dividends, fees) and responsibility for calculation/payment.
Treaty application – verifying conditions for reduced rates/exemptions (recipient residency, beneficial ownership), preparing certificates.
Forms and records – assistance with filings and maintaining records for audits.
Process improvement – suggesting internal procedures for timely and correct compliance.

Result: proper compliance and reduced risk of retroactive liabilities.

4. Digital assets taxation

Transaction classification – differentiating income types (trading, exchange, staking, airdrops), as tax treatment depends on nature.
Records and evidence – implementing standards (date, quantity, price, fees) for accurate gains/losses calculations.
Calculation and filing – preparing capital gains calculations and returns; explaining treatment upon fiat conversion or platform transfers.
Legal compliance – guiding on applicable domestic rules and administrative practice, highlighting changes and timely adjustments.

Result: lawful and secure handling of digital assets with minimized tax burden.

What Collaboration with Us Looks Like

Initial analysis – identifying tax risks and optimization opportunities.
Strategy definition – developing a personalized plan tailored to the client’s model.
Preparation and implementation – drafting required documentation and assisting in execution.
Representation – acting before the Tax Administration and courts.
Continuous support – monitoring regulatory changes and ensuring up-to-date compliance.

Examples of Completed Projects (Non-Confidential)

Corporate income tax optimization for an international IT company through R&D incentives.
Structuring IP transactions and tax treatment of licenses for a pharmaceutical client.
Tax planning for a non-resident individual earning income in Serbia and abroad.
Advising on capital gains tax for real estate sale in Belgrade.

Tijana Žunić Marić

Jelena Đukanović

Anja Berić

Marija Medić Racić

Frequently Asked Questions (FAQ)

1. Can tax incentives be used cumulatively?

In practice, certain incentives can be combined, but this depends on the type of benefit and applicable rules.

For example, employment incentives and R&D incentives can be used simultaneously if they do not apply to the same expenses.

Some incentives are mutually exclusive, and combining them may lead to rejection of returns or additional liabilities.

Our team analyzes all options, checks compatibility, and proposes optimal combinations to maximize benefits without compliance risks.

2. How are cryptocurrency incomes treated in Serbia?

Income from trading or investing in cryptocurrencies is taxed as capital gains at a 15% rate. The taxable base is the difference between the sale and purchase price, plus transaction costs.

Although the law provides clear rules, practical issues arise around proof of acquisition price and timing of obligations. Regulations change quickly, and practice is evolving.

Our team provides up-to-date guidance, assists with reporting and payments, and proposes lawful strategies to reduce obligations and avoid penalties.

3. Do individuals have to report foreign income?

All Serbian residents must report worldwide income, meaning both domestic and foreign earnings (salaries, business income, fees, dividends, interest, rent).

Non-residents report only Serbian-sourced income. Depending on the country of origin, tax treaties may apply to avoid double taxation.

We guide clients in correct reporting, treaty use, and planning to reduce obligations and ensure full compliance.

4. What is the statute of limitations for tax obligations?

The general statute of limitations in Serbia is five years from the first day of the year following the obligation’s due date.

However, this can be extended if the Tax Administration takes action (e.g., initiating an audit, issuing notices). Some taxes have specific limitation rules, so durations may differ.

Each case is unique, and mistakes can be costly. Our team provides precise guidance and monitors limitation periods to safeguard clients’ rights.

5. Does Zunic Law represent clients in tax disputes?

Yes, we have extensive experience representing clients in all types of tax disputes.

This includes proceedings before the Tax Administration during audits, filing appeals against decisions, as well as litigation before administrative and judicial bodies.

Tax disputes require not only legal expertise but also strategic negotiation skills and strong financial evidence.

Our goal is to protect clients from unfounded liabilities, minimize exposure to risks, and ensure legal certainty at every stage.