Data points
- Separate transfer pricing systems inside Bosnia and Herzegovina[1]
- 3 regimes
- Controlled transactions that trigger the Federation's annual form[1]
- BAM 500,000
- Group revenue that triggers the Federation master file and country-by-country report[2]
- EUR 750m
- Deadline for the annual transfer pricing forms[1]
- 31 March
- To produce documentation on request in the Federation[3]
- 45 days
- To produce documentation on request in Republika Srpska[4]
- 30 days
- Ceiling on a documentation fine in the Federation[3]
- BAM 100,000
- Stock ownership that makes parties related in Brčko District[1]
- 10%
Bosnia and Herzegovina has no single transfer pricing regime. Three tax jurisdictions each run their own, and the one that applies to your subsidiary follows where that subsidiary is registered, not where the parent sits.
The four facts to know:
- The Federation of Bosnia and Herzegovina, Republika Srpska and Brčko District each have their own corporate income tax law, their own transfer pricing rulebook and their own tax administration.
- Master files and local files are kept, not filed. They have to exist when the corporate income tax return goes in, then be produced within 45 days in the Federation or within 30 days in Republika Srpska.
- The annual reporting forms are due 31 March for the preceding year.
- Missing documentation costs the company up to BAM 100,000 in the Federation and up to BAM 60,000 in Republika Srpska.
Does Bosnia and Herzegovina have one transfer pricing regime or three?
Three. The Federation of Bosnia and Herzegovina (FBiH), Republika Srpska and Brčko District each set their own corporate income tax law, their own transfer pricing rulebook and their own tax administration, according to the OECD transfer pricing country profile for Bosnia and Herzegovina[1] updated in January 2026.
A Sarajevo subsidiary files under FBiH rules. A Banja Luka subsidiary files under Republika Srpska rules. A group holding entities on both sides of that line complies with both regimes separately, and nothing is ever consolidated across it.
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| Jurisdiction | Tax administration | Documentation model | Source |
|---|---|---|---|
| Federation of Bosnia and Herzegovina | Tax Administration of the Federation of Bosnia and Herzegovina | Master file and local file, kept not filed, plus annual forms | OECD |
| Republika Srpska | Tax Administration of Republika Srpska | One unified documentation duty, kept not filed, plus an annual declaration | OECD |
| Brčko District | Brčko District Finance Directorate | No master file or local file. Transfer pricing data goes inside the return | OECD |
Both the Federation and Republika Srpska amended their rules in 2024. The Federation's rulebook amendment came into force on 21 November 2024[2], so guidance published before then quotes superseded figures. Every number on this page carries the year it took effect.
What are the master file requirements in Bosnia and Herzegovina?
Only the Federation has a clear master file trigger, and only for large groups. A master file is required there once consolidated group gross revenue exceeds EUR 750 million, a threshold that replaced BAM 1.5 billion with effect from 1 January 2025. Brčko District requires no master file at all.
Republika Srpska is unsettled and this page will not resolve it quietly. The January 2026 OECD profile records a master file as required there. The enabling text describes one unified documentation duty for any taxpayer with related party transactions, with no revenue trigger of the Federation's kind. Treat the Republika Srpska master file position as open and confirm it with your local adviser.
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| Jurisdiction | Master file required | Threshold | Source |
|---|---|---|---|
| Federation of Bosnia and Herzegovina | Yes, for large multinational groups | Consolidated gross revenue above EUR 750 million, from 1 January 2025 | Tax Administration of the Federation of Bosnia and Herzegovina |
| Republika Srpska | Not confirmed. Sources conflict | No separate revenue trigger stated | OECD |
| Brčko District | No | Not applicable | OECD |
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What are the local file requirements in Bosnia and Herzegovina?
Every taxpayer with controlled transactions needs entity level documentation, and there is no size exemption in the Federation or in Brčko District. The file covers the entity's controlled transactions, the method chosen and the benchmarking behind it.
The Federation and Republika Srpska both require the documentation to exist at the corporate income tax return date[4]. Brčko District does it differently: there is no standalone file, and the transfer pricing data goes into the return itself. The Federation and Republika Srpska both prefer local comparables for benchmarking.
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| Jurisdiction | Local file obligation | Trigger | Source |
|---|---|---|---|
| Federation of Bosnia and Herzegovina | Documentation must exist when the return is filed. A shortened report is allowed in limited cases | Any related party transactions, no size exemption | Tax Administration of the Federation of Bosnia and Herzegovina |
| Republika Srpska | Documentation on hand at return filing | BAM 50,000 of related party transactions, from secondary sources only | Republika Srpska |
| Brčko District | No formal local file. Transfer pricing data goes in the return, on Form 1101 Annexes 12 and 13 | No materiality threshold | OECD |
The Republika Srpska figure of BAM 50,000 comes from secondary sources rather than primary statute text, so it is labelled as such here rather than stated flat.
What are the documentation thresholds in Bosnia and Herzegovina?
Read them as one table, not as a single national number. The Federation has the most granular set: no threshold for the documentation itself, BAM 500,000 for the annual form, and EUR 750 million for the master file and country-by-country reporting.
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| Jurisdiction | Obligation | Threshold | Effective | Source |
|---|---|---|---|---|
| Federation of Bosnia and Herzegovina | Local documentation | All taxpayers with related party transactions. No threshold | 2026 | Tax Administration of the Federation of Bosnia and Herzegovina |
| Federation of Bosnia and Herzegovina | Form TP-902 | Controlled transactions above BAM 500,000, about EUR 254,033 | 2026 | OECD |
| Federation of Bosnia and Herzegovina | Master file and country-by-country report | Consolidated revenue above EUR 750 million | From 1 January 2025 | Tax Administration of the Federation of Bosnia and Herzegovina |
| Republika Srpska | Documentation | BAM 50,000, from secondary sources | 2026 | Republika Srpska |
| Republika Srpska | Annual controlled transactions declaration | BAM 700,000 | 2026 | Tax Administration of Republika Srpska |
| Brčko District | Documentation inside the return | All taxpayers. None | 2026 | OECD |
A sanity check on the euro figures. The convertible mark is pegged at 1.95583 BAM to 1 euro under the currency board, so BAM 500,000 is about EUR 254,033, and the EUR 750 million master file trigger is roughly BAM 1.47 billion.
Which transfer pricing forms does each jurisdiction require?
The Federation uses named transfer pricing forms. Brčko District builds the data into the return. Republika Srpska requires an annual declaration under its own transfer pricing rulebook[5], whose official form code is not confirmed from any government or gazette source.
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| Jurisdiction | Form | Trigger | Source |
|---|---|---|---|
| Federation of Bosnia and Herzegovina | TP-902, the annual controlled transactions report | Controlled transactions above BAM 500,000 | OECD |
| Federation of Bosnia and Herzegovina | TP-900, the double tax relief claim | A relief claim | Tax Administration of the Federation of Bosnia and Herzegovina |
| Federation of Bosnia and Herzegovina | CBC-901, the country-by-country report | Group above EUR 750 million | Tax Administration of the Federation of Bosnia and Herzegovina |
| Republika Srpska | Annual declaration of controlled transactions. Form code not confirmed | Above the ministerial threshold, reported as BAM 700,000 | Tax Administration of Republika Srpska |
| Brčko District | Form 1101, Annexes 12 and 13, plus Form 1102 | All taxpayers with related party transactions | OECD |
When is Bosnia and Herzegovina transfer pricing documentation due?
The documentation itself has no filing date, because it is never filed. It has to exist when the corporate income tax return goes in, and be handed over on request. The annual forms do have dates, and both fall on 31 March.
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| Obligation | Jurisdiction | Deadline | Source |
|---|---|---|---|
| Form TP-902 | Federation of Bosnia and Herzegovina | 31 March, with the corporate income tax return | OECD |
| Form 1102 | Brčko District | 31 March, with the corporate income tax return | OECD |
| Documentation on request | Federation of Bosnia and Herzegovina | Within 45 days | Tax Administration of the Federation of Bosnia and Herzegovina |
| Documentation on request | Republika Srpska | Within 30 days | Republika Srpska |
| Corporate income tax return | Republika Srpska | 90 days after the year end, so 31 March for calendar year filers | Republika Srpska |
| Country-by-country report | Federation of Bosnia and Herzegovina | Within 12 months of the group's reporting period end | OECD |
What language must the documentation be in?
In the Federation, an official Bosnia and Herzegovina language. Only the master file may be prepared in English, and the tax administration can still demand a translation of it. Brčko District's Form 1102 must be in an official language too, with no English provision found. The Republika Srpska language rule is not confirmed from any source, so do not assume English is accepted there. All amounts are in convertible marks.
Does Bosnia and Herzegovina require country-by-country reporting?
The Federation does, on Form CBC-901, once consolidated group revenue reaches EUR 750 million. The report is due within 12 months of the group's reporting period end. Brčko District has no country-by-country obligation at all.
Two gaps are worth naming. The Federation's notification mechanics, meaning how the local entity tells the tax administration which group entity files and where, are not stated to a citable standard. The Republika Srpska threshold and deadline could not be verified from any source. Neither is stated here as fact.
What are the penalties for getting Bosnia and Herzegovina transfer pricing wrong?
Each jurisdiction sets its own, and the bands differ sharply. The Federation reaches BAM 100,000 on the company and fines the responsible individual separately. Republika Srpska has a higher floor and a lower ceiling. Brčko District defines no transfer pricing specific penalty at all.
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| Jurisdiction | Offence | Fine | Source |
|---|---|---|---|
| Federation of Bosnia and Herzegovina | No documentation, non-arm's length dealing, or failure to submit on request | BAM 3,000 to BAM 100,000 on the company, about EUR 1,524 to EUR 50,867, plus BAM 2,500 to BAM 10,000 on the responsible person. Fines rise 50% on a repeat offence | Tax Administration of the Federation of Bosnia and Herzegovina |
| Republika Srpska | Lacking documentation, or failing to deliver it within 30 days | BAM 20,000 to BAM 60,000 on the company, about EUR 10,173 to EUR 30,500, plus BAM 5,000 to BAM 15,000 on the responsible person, from secondary sources | Republika Srpska |
| Brčko District | Documentation default | No transfer pricing specific penalty defined. General tax administration penalties may apply. Amount not confirmed | OECD |
The Republika Srpska band for the responsible person is secondary sourced. The Brčko District amount stays unconfirmed, because its own profile response says transfer pricing penalties are not defined in its legislation and no primary figure exists to quote.
Can you get an advance pricing agreement in Bosnia and Herzegovina?
No. None of the three jurisdictions runs an advance pricing agreement programme. Rulings are available in the Federation and in Republika Srpska, which can give some comfort on a position, but a ruling is not a pre-agreed pricing method and does not bind the way an agreement would.
There is one safe harbour, and it sits in the Federation. A 5% cost based fee is accepted for listed low value support services, such as accounting, information technology, payroll and legal, where the provider does not serve independent parties. That removes the need for a full benchmarking study on those services alone.
Bosnia and Herzegovina is not an OECD member. It is a member of the Inclusive Framework, and the OECD profile records the guidelines as followed partially, so the three tier model applies in spirit rather than by direct adoption.
How do multinationals comply with Bosnia and Herzegovina transfer pricing rules?
The sequence for a foreign parent, run once per local entity:
- Establish where each entity is registered, because that fixes which of the three regimes applies to it.
- Test the related party relationships against that jurisdiction's own threshold: 25% in the Federation and Republika Srpska, 10% plus family holdings in Brčko District.
- Check whether the group passes EUR 750 million of consolidated revenue, which brings in the Federation master file and country-by-country report.
- Build the benchmarking on local comparables, which the Federation and Republika Srpska both prefer.
- Have the documentation complete before the corporate income tax return goes in, not after.
- File the annual form by 31 March, and keep the file ready to hand over in 45 days or 30 days depending on the jurisdiction.
How we help with Bosnia and Herzegovina transfer pricing
Bosnia and Herzegovina asks three different things of the same group, and the cost of guessing which one applies is a BAM 100,000 fine. We work out which regime each entity sits in, build the benchmarking on local comparables, prepare the files in the language each jurisdiction accepts, and keep the 31 March dates and the on-request windows tracked. See how our transfer pricing software works.
Book a demo to map your Bosnia and Herzegovina obligations jurisdiction by jurisdiction.
Official sources
5 sources
- 1.OECD. Transfer pricing country profile: Bosnia and Herzegovina (January 2026)
- 2.Tax Administration of the Federation of Bosnia and Herzegovina. Rulebook on Transfer Pricing, consolidated text
- 3.Tax Administration of the Federation of Bosnia and Herzegovina. Law on Corporate Income Tax of the Federation of Bosnia and Herzegovina
- 4.Republika Srpska. Corporate Income Tax Law of Republika Srpska
- 5.Tax Administration of Republika Srpska. Rulebook on Transfer Pricing and the methods for determining them
Article by
Logan Jackonis
Head of Services & Operations, Commenda
Logan leads Commenda’s Services and Operations team, helping controllers, heads of tax, and finance leaders navigate international expansion. He built a global expert network across 70 countries and previously worked in management consulting across the Middle East and Southeast Asia.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
