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

Simpson Thacher & Bartlett and MinterEllisonRuddWatts were among the firms that advised on the deal
AI will mean fewer entry-level roles in tax but also the emergence of new jobs, according to tax expert Isabella Barreto
As World Tax unveils its much-anticipated rankings for 2026, we focus on standout performances by PwC, KPMG and Deloitte across the Asia-Pacific region
The partnership model was looking antiquated even before the UK chancellor’s expected tax raid on LLPs was revealed. An additional tax burden may finally kill it off
The US’s GILTI regime will not be forced upon American multinationals in foreign jurisdictions, Bloomberg has reported; in other news, Ropes & Gray hired two tax partners from Linklaters
APAs should provide a pragmatic means to agree to an arm's-length outcome for an Australian entity and for the ATO, the tax authority said
Overall revenues and average profit per partner also increased in the UK, the ‘big four’ firm revealed
Increasingly complex reporting requirements contributed towards the firm’s growth in tax, it said
Sector-specific business taxes, private equity tax treatment reform and changes to the taxation of non-residents are all on the cards for the UK, authors from Herbert Smith Freehills Kramer predict
The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
Gift this article