Serbia: Treaty analysis: Serbia ratifies DTA with South Korea

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: Treaty analysis: Serbia ratifies DTA with South Korea

Rafailovic

Aleksandra Rafailovic

On February 24 2016, Serbia expanded its double tax treaty network by ratifying the Agreement for the avoidance of double taxation with respect to taxes on income, signed with the Republic of Korea on January 22 2016.

The treaty closely follows the standard OECD contract model, but differs in terms of the withholding tax rates applicable, which have been defined as follows:

  • Dividends

  • 5% ( if the recipient company holds at least 25% of the dividend-paying company)

  • 10% ( in all other cases);

  • Interest – 10%;

  • Royalties

  • 5% (for the use of, or the right to use, any copyrights of literary, artistic or scientific work including cinematography films, films or tapes for television or radio)

  • 10% (applicable for the use of, or the right to use any patent, trademark, design or model, plan, secret formula or process as well as industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience).

Some other specific details include:

  • A building site or construction or installation project constitutes a permanent establishment only if it lasts more than 12 months.

  • Penalty interest rate shall not be regarded as interest for purposes of this Agreement (Article 11)

By signing the above-mentioned treaty, South Korea also becomes one of the countries exempt from the withholding tax on service fees paid to non-resident legal entities which was introduced in Serbia as of March 1 2016.

Following the ratification of the agreement and the publishing of the ratification law in the Official Gazette – International Treaties No. 4/2016, the treaty becomes officially binding and will enter into force as of January 1 2017.

Aleksandra Rafailovic (aleksandra.rafailovic@eurofast.eu)

Eurofast Global Belgrade

Tel: +381 11 3241484

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole
Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team
Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found
Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes
While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions
While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard
Moore, founding partner of the Chicago tax boutique which bears her name, shares her career wisdom for ITR’s new Women in Tax interview series
But partners at the firm admit that jumping ship to the US would not be as easy as some believe
Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created
Gift this article