The network of effective double taxation treaties between Serbia and other countries has been changed in relation to the previous year – treaties with San Marino and Indonesia are in force, while treaty with Malesia is no longer in effect. In addition, as a result of Multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (MLI) from 1 January 2019, treaties with the following countries are amended: Austria, France, Lithuania, Poland, Slovakia, Slovenia and United Kingdom.

The list of 59 double taxation treaties of Serbia effective as at 1 January 2019 is presented in the attached document (including the most important changes prescribed by MLI):

Jurisdictions with a preferential tax system

If a foreign legal entity is located in a jurisdiction with a preferential tax system, the tax rate is 25%. In addition, the tax is paid on fees paid to a foreign person for all services, regardless of the place of delivery or use. From 1 January 2019 San Marino is no longer on the list of jurisdictions with a preferential tax system.

The list of jurisdictions with a preferential tax system applicable as of  1 January 2019 is presented as attachment.

For previous editions of KPMG Tax Alerts please visit the following web page:

KPMG Tax Alerts

KPMG Tax & Legal Department
KPMG d.o.o. Beograd
Kraljice Natalije 11
Belgrade, Serbia
Office: +381 11 20 50 500

tax@kpmg.rs