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Costs of investment projects in Serbia can be reduced as a result of highly competitive and diverse investment incentives.

Investment Incentives Outline
Financial Incentives
  State Grants for Greenfield and Brownfield Projects
  The National Employment Service Grants
Tax Incentives
  Corporate Income Tax Holiday
  Corporate Income Tax Credits
  Carrying Forward of Losses
  Salary Tax Social Insurance Charges Exemptions
  Annual Income Tax Deductions
  Value Added Tax Exemptions in Free Zones
  Corporate Income Tax Holiday
  Double Taxation Relief
Other Incentives
  Customs-Free Imports of Raw Materials and Semi Finished Goods
  Customs-Free Imports of Machinery and Equipment
  Local Incentives

FINANCIAL INCENTIVES

State Grants for Greenfield and Brownfield Projects

Up till now, foreign and local companies have been approved EUR 252 millions of nonrefundable funds for the projects exceeding EUR 1.3 billion providing for 44,046 new jobs in Serbia. This incentive scheme has already benefited a large number of world-class companies, namely Michelin, Yura Corporation, Golden Lady, Gorenje, Henkel, Kronospan, Leoni, Pompea and many more.

Based on the Serbian Government Decree and provided by the budget of the Republic of Serbia state grants are offered for Greenfield and Brownfield projects in all industries except primary agriculture, hospitality industry, retail and the production of synthetic fibers and coal. The non-refundable state funds are offered in the range between EUR 4,000-10,000 per new job created within 3 years of the day of signing the contract on awarding funds.

STANDARD-SCALE PROJECTS
 
Manufacturing
Internationally Marketable Services
Tourism
Eligible
Investments
Investments
in
underdeveloped
regions (4th group) and
devastated regions
Investments
in 1st, 2nd and 3rd group of
local administrations
Investments in
all regions of
the Republic of
Serbia
Investments
in strategic
projects
in all
regions of
the Republic
of Serbia
Grant Amount (EUR)
EUR 4,000 –10,000 per job created
Investment Amount
EUR 0.5 mil
EUR 1 mil
EUR 0.5 mil
EUR 5 mil
Minimum Number of New Jobs Created
50
50
10
50
LARGE-SCALE PROJECTS
Eligible Investments
Investment of Special Importance
Large Investment Projects
Mid-Sized Investment Projects
Grant Amount (EUR)
Up to 17% of the total
investment
Up to 17% of the total investment
Up to 20% of the total investment
Up to 10% of the total investment
The Minimum Investment Amount
EUR 200 mil
EUR 100 mil or greater
between EUR 50 mil and EUR 100 mil
EUR 50 mil
The Minimum Number of New Jobs Created
1,000
300
300
150

Program Criteria

State funds are awarded upon the scoring based on the following criteria:
    • investor’s references,
    • participation of domestic suppliers,
    • investment sustainability,
    • introduction of new technologies and transferability of knowledge and skills to domestic suppliers
    • effects on human resources,
    • international sales volume,
    • economic effects of the project, and
    • effects on the development of the local community

Pay-Out Plan

For Greenfield investments or Brownfield investments that include reconstruction of facilities - 4 equal installments of 25% throughout the project’s lifetime and upon fulfilling the following conditions:
  1. after concluding the contract for sale or lease of land or building or submitting an extract from the cadastre or land registry;
  2. after obtaining the construction approval which may not be older than three years from the date the request to disburse funds is submitted;
  3. after obtaining the right-to-use permit;
  4. after achieving full employment envisaged by the investment project.
For Brownfield investments which include adaptation of facility space - 3 equal installments of 33% throughout the project’s lifetime and upon fulfilling the following conditions:
  1. after concluding the contract for sale or lease of building or submitting an extract from the cadastre or land registry;
  2. after obtaining the approval of works;
  3. after achieving full employment envisaged by the investment project.
For Brownfield investments that do not require reconstruction or adaptation of facilities and for export related services projects encompassing the lease of business premises - funds are disbursed in two installments upon fulfilling the following conditions:
  1. 30% upon concluding a purchase contract for the building, or upon submitting a property deed, usage permit, or, in the case of leased space, a lease agreement and right-to-use permit;
  2. 70% after achieving full employment envisaged by the investment project.

The National Employment Service Grants

In addition to funds aimed at attracting Greenfield and Brownfield foreign investments, the National Employment Service is also providing several programs regarding endowments for employers.

Program
Grant Amount per Employee
Employment Subsidies Program
EUR 850-1,700
Apprentice Program
EUR 170-210
Re-Training Program
EUR 850

TAX INCENTIVES

Highly competitive tax regime accompanied with a number of related incentives makes Serbia highly conducive to doing business

Corporate Income Tax Holiday

Companies are exempt from Corporate Income Tax for a period of 10 years starting from the first year in which they report taxable profit if they invest in fixed assets an amount exceeding approximately EUR 9 million, and throughout the investment period they employ at least 200 additional employees.

Corporate Income Tax Credits

The amount of tax payable can be reduced by 20% of the amount invested in fixed assets for the respective tax period. This reduction cannot exceed 33% of the total tax liability for a single year. If not used entirely in the course of one year, this tax credit can be carried forward for a maximum period of 10 years. For small companies, tax credit of 40% is granted for fixed assets investments in the current year and may not exceed 70% of the tax due.

Carrying Forward of Losses

Net operating losses stated in the tax return can be carried forward for 5 years. Capital losses may be carried forward and offset against future capital gains over a period up to 5 years. The carryback of losses is not permitted.

Salary Tax Social Insurance Charges Exemptions

A company who hires new personnel from certain categories of workers on a permanent basis is exempt from paying salary tax over the period of 3 or 2 years.

The employer is exempt of paying SIC for a period of 3 years for apprentices aged fewer than 30 registered as unemployed by the National Employment Service and for disabled persons.

In case of employees under 30 registered as unemployed for no less than 3 months, those aged 50 or older registered as unemployed for no less than 6 months and received unemployment compensations as well as all employees aged between 45-50 the release period would last 2 years.

Annual Income Tax Deductions

The annual income tax due by Serbian residents on net worldwide income in excess of a prescribed threshold (3 average annual salaries) is levied at progressive rates ranging from 10% to 15%. The annual income is taxed if exceeding the amount of threefold the average annual salary in Serbia. The tax rate is 10% for the annual income amounted in the range between 3 and 6 times average annual salary in Serbia, and 15% for the part of the annual income exceeding 6 times average annual salary in Serbia. The taxable income is further reduced by 40% of an average annual salary for the taxpayer and by 15% of an average annual salary for each dependent member of the family. The total amount of deductions cannot exceed 50% of the taxable income.

Avoiding Double Taxation

If a taxpayer already paid tax on the profit generated abroad, he is entitled to a Corporate Income Tax credit in Serbia to the already paid amount. The same right is enjoyed by a taxpayer who earns revenue and pays Personal Income Tax in another country, provided there is a Double Taxation Treaty with that country.

Double Taxation Agreements (DTA) Signed by Serbia

OTHER INCENTIVES

Customs-Free Imports of Raw Materials and Semi Finished Goods

Foreign investors in Serbia can enjoy the benefit of customs free import of raw material and semi finished goods for export oriented production. This benefit can either be achieved by operating in one of the free zones in Serbia or by a permit from custom office for outward processing production. In both cases finished products must be 100% designated for export.

Customs-Free Imports of Machinery and Equipment

Foreign investors are exempt from paying customs duty on imported equipment and machinery which represents the share of a foreign investor in a capital of a company in Serbia.

Local Incentives

A wide array of incentives is also available at the local level, varying in scope and size from one city to another. The major ones comprise the following:
  • City construction land lease fee exemptions or deductions, including the option of paying in installments, with the prior consent of the Serbian Government;
  • City construction land development fee relief such as fee exemptions or discounts for one-off payments.
In the Serbian Province of Vojvodina, investors are awarded financial grants for new employment, amounting to RSD130,000 (approx. EUR 1,122) with the possibility of receiving additional RSD 20,000 (approx. EUR 173) for employing person older than 50 years old, this totals RSD 150,000 (approx. EUR 1,295).
 
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