Serbia: Treaty analysis: Serbia and Norway double taxation agreement

Ivana Blagojevic

On September 4 2015, the Serbian Government approved the draft Treaty for Avoidance of Double Taxation, signed between Serbia and Norway on June 17 2015. The treaty's entry into force is pending ratification from both parties.

The new double tax treaty (DTT) between Serbia and Norway provides, inter alia, for the following:

• A withholding tax on dividends at the rate of 5% (in case of at least 25% participation) or 15% (all other cases). The currently applicable treaty signed between the Socialist Federal Republic of Yugoslavia (SFRY) and Norway in 1983 prescribes a standard 15% rate.
• A withholding tax rate of 10% on interest (0% according to the currently applicable treaty)
• A withholding tax rate of 5% or 10% on royalties (10% according to the currently applicable treaty)

Following both parties' ratification of the new agreement and its subsequent entry into force, the old DTT between SFRY and Norway will no longer affect either jurisdiction. The treaty will become effective on January 1 of the year following the year during which it enters into force.

Ivana Blagojevic (ivana.blagojevic@eurofast.eu)
Eurofast Belgrade Office
Tel: +381 113241484
Website: www.eurofast.eu

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