Transfer Pricing Documentation: Regional Requirements and Best Practices

Transfer pricing compliance has become increasingly important across Southeast Europe. Tax authorities in all six jurisdictions we cover — Serbia, Montenegro, Bosnia and Herzegovina, North Macedonia, Slovenia, and Croatia — now actively review related-party transactions. This article outlines current documentation requirements and practical compliance approaches.

Documentation requirements vary by jurisdiction, with different thresholds, filing deadlines, and content specifications. EU members Slovenia and Croatia sit closest to the OECD-aligned master file / local file structure. Serbia, Montenegro, Bosnia and Herzegovina, and North Macedonia each apply variants that share the same methodology but diverge in thresholds and deadlines.

Companies operating across multiple countries should develop a coordinated approach that satisfies local requirements while maintaining consistency in methodology and documentation. A single regional functional analysis, extended with country-specific local files and benchmarking, is typically more efficient than standalone documentation per entity.

Best practices include maintaining contemporaneous documentation rather than reconstructing at year-end, conducting regular benchmarking updates, and proactively reviewing significant transactions before they are executed. Defence files for high-value transactions should be prepared in parallel with the transaction itself, not after a tax inquiry lands.