Serbia: Serbia and UAE sign double tax treaty on income and capital

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Serbia: Serbia and UAE sign double tax treaty on income and capital

vucenovic.jpg

Gordana Vucenovic

In January 2013, the double tax treaty (DTT) with respect to taxes on income and capital between Serbia and the United Arab Emirates was signed and on March 15 2013 the Parliament of Serbia ratified the treaty.

Article 5: Permanent establishment

The permanent establishment (PE) is considered as the fixed place of business such as a place of management, branch, office, factory, workshop, mine, oil or gas well. The term also includes:

  • A building site, construction , assembly or installation when it lasts more then 18 months; and

  • The services are provided for a period or periods exceeding in the aggregate 183 days in any 12 month period, and these services are performed for the same project or for connected projects through one or more individuals who are present and performing such services in that other state.

Article 6: Income from immovable property

Income gained from immovable property including income from direct use, letting or other as well as income from agriculture and forestry may be taxed in the state where the property is located.

Article 7: Business profits

The profits of an enterprise shall be taxable in the other contracting state, if the enterprise carries on business there, through a permanent establishment situated therein, provided that the profits of the enterprise are taxed only as much as is attributable to that permanent establishment.

Article 10: Dividends

If the beneficial owner of the dividends is a resident of the other contracting state, the tax may be charged as follows:

  • 5% of the gross amounts of the dividends if the beneficial owner is a company which holds directly or indirectly at least 5% of the capital of the company paying the dividends;

  • 10% of the gross amounts of dividends in all other cases.

Article 11: Interest; Article 12: Royalties

The withholding tax rate at 10% applies at source in both cases if the beneficial owner of the interest/royalties is the resident of the other contracting state.

Article 13: Capital gain

Gains derived by a resident of a contracting state from the alienation of immovable property situated in the other contracting state may be taxed in that other state, except gains of the resident of a contracting state from the alienation of ships or aircraft operated in international traffic shall be taxable only in that contracting state.

Article 23: Elimination of double taxation

If the resident of a contracting state derives income or owns capital that may be taxed in the other contracting state, the contracting state shall allow deduction from the tax on the income of that resident, in the amount equal to the income tax paid in that other state.

Article 25: Exchange of information

Same provisions as seen in the OECD model convention.

Analysis

It is expected that based on this DTT and the other agreements regarding cooperation in the fields of defence, mutual incentives and protection of investments, the range of potential for cooperation between Serbia and the UAE will significantly grow. The first announced investments of the UAE to Serbia based on the above agreements are expected to be of around $500 million for agriculture and $220 million for military industry, and partnership in the air transportation industry.

Gordana Vucenovic (gordana.vucenovic@eurofast.eu)
Eurofast Global, Belgrade Office/Serbia

Tel: +381 11 3241 484

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

If Trump continues to poke the world’s ‘middle powers’ with a stick, he shouldn’t be surprised when they retaliate
The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas
Zion Adeoye, a tax specialist, had been suspended from the African law firm since October over misconduct allegations
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said
Trump announced he will cut tariffs after India agreed to stop buying Russian oil; in other news, more than 300 delegates gathered at the OECD to discuss VAT fraud prevention
Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said
The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
User-friendly digital tax filing systems, transformative AI deployment, and the continued proliferation of DSTs will define 2026, writes Ascoria’s Neil Kelley
Case workers are ‘still not great’ but are making fewer enquiries, making the right decision more often and are more open to calls, ITR has heard
Gift this article