Serbia: Serbia signs 66th double tax treaty

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

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 & bottom lb ros

More from across our site

ITR’s most interesting stories of the year covered ‘landmark’ legal battles, pillar two, AI’s relationship with transfer pricing and more
Chinwe Odimba-Chapman was announced as Michael Bates’ successor; in other news, a report has found a high level of BEPS compliance among OECD jurisdictions
The tool, which will automatically compute amount B returns, requires “only minimal data inputs”, according to the OECD
The rules are intended to implement the substance of an earlier OECD report in its entirety
While new technology won’t replace the human touch, it could help relieve companies’ staffing issues, EY’s David Helmer and Daren Campbell tell ITR
The firm said the financial growth came from increased demand for its AI services and global tax reform advice
Chrystia Freeland had also been the figurehead of Canada’s controversial digital services tax adoption, which stoked economic tensions with the US
Panama has no official position on pillar two so far and a move to implement in Costa Rica will face rejection, experts tell ITR
The KPMG partner tells ITR about Sri Lanka’s complex and evolving tax landscape, setting legal precedents through client work, and his vision for the future of tax
Overall turnover at the firm also reached a record £8 billion; in other news, Ashurst and Dentons announced senior tax partner hires
Gift this article