Serbia: Serbia signs 66th double tax treaty

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

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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

Serbia: Serbia signs 66th double tax treaty

Rafailovic

Aleksandra Rafailovic

On December 15 2015, the Republic of Serbia and the Grand Duchy of Luxembourg signed an agreement on avoidance of double taxation, which is in the process of ratification in the parliaments of both countries.

The agreement is based on a standard contract model of the OECD Model Convention and it applies to corporate profit tax, income tax and property tax.

The agreement allows a tax credit for resident taxpayers who earn income through a permanent establishment in the other country in amount of the income tax that has been paid in that other country. Per the law on corporate income tax of the Republic of Serbia, the tax credit cannot exceed the amount that would be calculated if using the standard method of tax calculation applicable for income realised abroad.

The rates of withholding tax to be applied on the basis of the agreement are as follows:

  • Dividends: 5% in case of at least 25% participation or 10% in all other cases;

  • Interest: 10%; and

  • Royalties: 5% to 10%, depending on the type of compensation.

The newly signed agreement reduces the tax burden for taxpayers who would otherwise have to pay tax in both Serbia and Luxembourg and as such will encourage capital investments between the two countries.

The agreement shall enter into force after the ratification by both parties and will be effective from January 1 of the year after ratification occurs.

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

CIT as a proportion of total tax revenue varied considerably across OECD countries, the report also found, with France at 6% and Ireland at 21.5%
Erdem & Erdem’s tax partner tells ITR about female leader inspirations, keeping ahead of the curve, and what makes tax cool
ITR presents the 50 most influential people in tax from 2025, with world leaders, in-house award winners, activists and others making the cut
Cormann is OECD secretary-general
Woldenberg is CEO of Chicago toymaking company Learning Resources
Lula, as he is commonly known, is Brazil’s president
Agarwal is director for indirect tax operations at shopping mall operator Majid Al Futtaim
Perez is global practice leader of Alvarez & Marsal Tax
Monaghan is CEO of the Fair Tax Foundation
Roth is Luxembourg’s finance minister
Gift this article