PracticesTax Law
Practice area

Tax Law

Compliance, planning and incentives for companies, entrepreneurs and individuals, with representation before the Tax Administration and the courts.

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Timely and accurate tax compliance is a legal duty and the foundation of reputation, stability and long-term sustainability.

In practice even the smallest error can carry significant financial consequences, while a well-designed tax strategy substantially reduces liabilities and opens space for investment.

With increasingly complex domestic and international rules and constant legislative change, planning and compliance have become essential for businesses and individuals alike.

Our approach combines legal certainty with commercial efficiency: every client receives an analysis of tax risk and opportunity, along with a clear optimisation plan and a focus on correcting irregularities before they cause consequences.

Key practice areas

What we handle

Eleven areas across corporate, entrepreneur and private client work.

01

Corporate tax compliance and optimisation

  • Review of accounting policies, returns and supporting documentation to eliminate discrepancies before an audit.
  • Lawful planning that reduces the burden: timing of income and expenses, depreciation and value adjustments, credits and incentives.
  • Risk mapping of red flags such as undocumented expenses or late payment interest, with remediation plans.
  • Pre-transaction tax due diligence on target companies.
  • Operational support: forms, records and explanations for the Tax Administration, and training for finance teams.
02

Employment-related tax incentives

  • Eligibility screening for incentives on new hires, young employees, returnees and shortage occupations, including time limits and overlaps.
  • Confirmations, statements and internal acts, and the records the authorities require.
  • Compensation models that maximise incentives without reclassification risk.
  • Monitoring of retention obligations and the risk of retroactive loss of an incentive.
03

R&D tax incentives

  • Identification of qualifying activities and the line between R&D and routine operations.
  • Granular expense tracking across materials, labour, contractors and prototypes.
  • R&D files with narrative and financial justification, internal acts and technical documentation.
  • Optimal use of the incentive — deduction or credit — aligned with the annual CIT filing.
04

Taxation of intellectual property

  • Structuring of IP ownership and use through agreements and internal acts.
  • Treatment of royalties, licence fees and R&D and maintenance costs.
  • Contracts, reports and explanations required in Tax Administration audits.
  • Local compliance on source of income, place of taxation and record keeping.
05

Entrepreneurs: income tax compliance

  • Choice of business form and tax regime based on revenue, costs and growth plans.
  • Obligation calendars, returns and internal accuracy checks.
  • Rules for documenting and classifying deductible costs.
  • Advice on thresholds, activity changes and mid-year regime shifts.
06

Entrepreneurs: VAT and business taxation

  • Assessment of the obligation or benefit of VAT registration, with applications and records.
  • Controls on e-invoices, postings and the conditions for input VAT deduction.
  • Special regimes: exemptions for exports and specific services, place of supply and advance payments.
  • Alignment of invoicing, contracts and logistics with VAT rules.
07

Entrepreneurs: the independence test

  • Assessment of the client–contractor relationship against the statutory indicators.
  • Contract clauses that support independence and avoid reclassification as employment.
  • Operational adjustments: multiple clients, own equipment, responsibility for results.
  • Evidence and internal policies prepared for audit.
08

Individuals: residency and international taxation

  • Determination of residency under domestic law and tax treaties, preventing dual residency conflicts.
  • Pre-relocation advice on income, property and capital gains taxes and reporting duties.
  • Reporting of worldwide income, with records, deadlines and foreign certificates.
  • Forms, statements and supporting documents for filing.
09

Individuals: capital gains tax

  • When capital gains arise on real estate, shares and instruments, and the exemptions available.
  • Cost basis records: acquisition price, investments and transaction costs, with FX adjustments.
  • Use of losses through offset and carry-forward.
  • Filings and calculations prepared to minimise audit risk.
10

Individuals: withholding tax

  • When withholding applies to interest, dividends and fees, and who is responsible for calculation and payment.
  • Treaty conditions for reduced rates or exemptions, including residency and beneficial ownership certificates.
  • Filings and records maintained for audit.
  • Internal procedures for timely and correct compliance.
11

Individuals: taxation of digital assets

  • Classification of transactions: trading, exchange, staking and airdrops.
  • Record standards — date, quantity, price, fees — for accurate gain and loss calculation.
  • Capital gains calculations and returns, including treatment on conversion to fiat or transfer between platforms.
  • Guidance on domestic rules and administrative practice as they change.
How we work

What working with us looks like

Five stages, from the first analysis to continuing support.

01

Initial analysis

We identify tax risk and the opportunities for optimisation.

02

Strategy

We build a plan around the client’s model.

03

Preparation

We draft the documentation and support its implementation.

04

Representation

We act before the Tax Administration and the courts.

05

Ongoing support

We track regulatory change and keep compliance current.

Track record

Selected matters

A sample of recent work in the sector.

Incentives

CIT optimisation for an IT group

Reduced the effective burden for an international IT company through R&D incentives.

IP

Licence structuring for a pharmaceutical client

Structured IP transactions and the tax treatment of licences.

Private client

Non-resident with income in Serbia and abroad

Tax planning across both jurisdictions.

Capital gains

Belgrade property sale

Advised on capital gains tax on the sale of real estate.

What Clients Ask Us Most

Can tax incentives be combined?

Certain incentives can be used together, depending on the type of benefit and the rules that apply. Employment and R&D incentives, for instance, can run in parallel where they do not apply to the same expenses.

Some are mutually exclusive, and combining them can lead to rejected returns or additional liabilities. We check compatibility and propose the combination that maximises the benefit without compliance risk.

How is cryptocurrency income treated in Serbia?

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

Practical issues arise around proving the acquisition price and the timing of the obligation, and the rules change quickly. We assist with reporting and payment and propose lawful strategies to reduce the liability.

Do individuals have to report foreign income?

Serbian residents must report worldwide income: salaries, business income, fees, dividends, interest and rent. Non-residents report only Serbian-sourced income.

Depending on the country of origin, a tax treaty may apply to avoid double taxation. We guide clients on correct reporting and treaty use.

What is the limitation period for tax obligations?

The general period in Serbia is five years from the first day of the year following the due date.

It can be extended where the Tax Administration takes action, such as opening an audit or issuing a notice, and some taxes have their own rules. We monitor the periods to safeguard clients’ rights.

Does Zunic Law represent clients in tax disputes?

Yes — in proceedings before the Tax Administration during audits, in appeals against decisions and in litigation before administrative and judicial bodies.

Tax disputes require legal expertise alongside negotiation and strong financial evidence. Our aim is to protect clients from unfounded liabilities and limit exposure at every stage.

Next step

Let’s talk about your tax position

Tell us what you are filing, claiming or defending and we will set out the options.

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