Kosovo Transfer Pricing Documentation Requirements
Kosovo requires transfer pricing documentation without a threshold, produced within 30 days of a request, and an Annual Controlled Transaction Notice where controlled transactions, including loan balances, exceed EUR 300,000. A simplified 7 percent mark-up is available for low-value-adding services without a benchmark.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation Required | No threshold for the documentation itself | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EN / SQ / SR | Adjustment, penalties and interest where unsupported |
Controlled transaction notice ACTN
Annual filing | Controlled transactions, including loan balances, exceeding EUR 300,000 | By 31 March of the following year | Submission deadline The documentation must be filed with the tax authority by the date shown. | EN / SQ / SR | Yes |
Calculate your exact Kosovo deadline
Enter your entity’s fiscal year-end to return your exact Kosovo preparation or filing date. Available without registration.
Scope of the documentation obligation
The corporate income tax law and the related transfer pricing instruction set no threshold for preparing the local transfer pricing documentation, which is produced within 30 days of a request. Separately, a taxpayer whose controlled transactions, including the balance of loans, exceed EUR 300,000 in a fiscal year must file an Annual Controlled Transaction Notice by 31 March of the following year. There is no Country-by-Country reporting obligation in the regime as captured.
Distinctive features of the Kosovan regime
Two features distinguish the Kosovan regime. The first is the separation between the thresholdless documentation duty and the EUR 300,000 notice threshold, so that all taxpayers with controlled transactions document while only those above the notice level file the annual notice. The second is the simplified approach for low-value-adding intragroup services, under which the service provider applies a 7 percent mark-up on costs without needing to support it with a benchmark analysis, which reduces the compliance burden for routine services. Non-submission of the local documentation can lead to a price adjustment, additional income tax, penalties, and interest rather than a fixed documentation fine.
Benchmarking and comparables
In the absence of domestic comparable uncontrolled transactions, foreign comparables are recognised provided geographic and other influencing factors are analysed and appropriate adjustments made. Preference is given to comparables from the same year as the controlled transaction, although immediate previous-year comparables may be relied on where the comparability criteria are met. A fresh benchmarking search is not required every year: database searches are updated every three years where operating conditions are unchanged, with financial updates performed annually. The limitation period is six years from the corporate income tax return filing due date.
Frequently asked questions
When must a Kosovan taxpayer file the Annual Controlled Transaction Notice?
Where the aggregate value of its controlled transactions, including loan balances, exceeds EUR 300,000 in the fiscal year. The notice is filed by 31 March of the following year.
Is there a simplified approach for low-value services in Kosovo?
Yes. The service provider may apply a 7 percent mark-up on costs for low-value-adding intragroup services without supporting it with a benchmark analysis.
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.