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

Despite the decline in profitability, the firm’s tax advisory business delivered a 3.4% revenue growth
Firms are making use of inventories and ample profit margins to avoid or absorb the initial impact of higher tariffs, an OECD report found
While UN proposals to shift airline taxation from a residence-based system to a source-state one are not set in stone, ex-British Airways CEO Willie Walsh warns they would increase costs and complexity
Von Wobeser y Sierra’s head of tax shares best practices for resolving tax controversy and touts his firm’s founding partner as an exemplar of legal practice
ITR concludes its analysis of World Tax’s rankings for 2026 by highlighting the firms that stood out most on a global scale
Experts from law firm Kennedys outline the key tax disputes trends set to define 2026, ranging from increased enforcement to continued tariff drama and AI usage
They also warned against an ‘unnecessary duplication of efforts’ in UN tax convention negotiations; in other news, White & Case has hired Freshfields’ former French tax head
Awards
Submit your nominations to this year's WIBL EMEA Awards by 16 February 2026
Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
Further empowerment of HMRC enforcement has been praised, but the pre-Budget OBR leak was described as ‘shambolic’
Gift this article