Bosnia and Herzegovina Transfer Pricing Documentation Requirements
Bosnia and Herzegovina administers transfer pricing through its two entities, with the Federation requiring a Master File above EUR 750 million in group revenue and a Local File, supported by summary forms filed by 31 March. A cost-plus safe harbour applies to specific support services in the Federation.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Group consolidated revenue > EUR 750m (Federation of Bosnia and Herzegovina) | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | EN / local | Yes (up to EUR 50,000 in the FBiH; up to EUR 30,000 in the RS) |
Local File Required | Taxpayers with related-party transactions | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | Local language | Yes (up to EUR 50,000 in the FBiH; up to EUR 30,000 in the RS) |
TP forms TP 900 / TP 902
Annual filing | FBiH taxpayers with related-party transactions exceeding BAM 500,000 | By 31 March | Submission deadline The documentation must be filed with the tax authority by the date shown. | Local language | Yes |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
Bosnia and Herzegovina administers tax through two entities, the Federation of Bosnia and Herzegovina and the Republic of Srpska, and the transfer pricing rules apply at that level. In the Federation, a Master File is required for entities with consolidated group revenue above EUR 750 million, and a Local File is required of taxpayers with related-party transactions. A summary form of controlled transactions, the TP 902 form, must be prepared in the Federation where related-party transactions exceed BAM 500,000, signed by an authorised person and submitted with the corporate income tax return by 31 March for the previous year.
Distinctive features of the regime
The defining feature of the regime is its two-entity structure, under which the Federation and the Republic of Srpska set their own penalty ceilings, up to EUR 50,000 in the Federation and up to EUR 30,000 in the Republic of Srpska, and their own filing forms. The Federation also publishes a safe harbour of 5 percent on the total cost of specific administrative and support services that are not provided to third parties, while the Republic of Srpska does not prescribe a safe harbour, so the treatment of an intra-group service can differ between the two entities. A multi-year analysis is mandatory in the Federation and recommended in the Republic of Srpska.
Benchmarking and comparables
Foreign comparables are accepted where no local comparables can be identified in either entity. A multi-year analysis is mandatory in the Federation and recommended in the Republic of Srpska. The legislation does not prescribe the frequency of a fresh search, but following the OECD approach a fresh search is not required every year, with a roll-forward and financial update of the comparables accepted while documentation is prepared annually. The general limitation period is five years for direct taxes in both entities, with no limit in the Federation in cases such as falsely prepared returns or intentional concealment.
Frequently asked questions
How does the two-entity structure affect transfer pricing in Bosnia and Herzegovina?
The Federation of Bosnia and Herzegovina and the Republic of Srpska set their own penalty ceilings, filing forms, and safe-harbour treatment. The Federation publishes a 5 percent support-services safe harbour, while the Republic of Srpska does not.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.