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      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in relation to the previous year – treaties with San Marino and Indonesia are in force, while treaty with Malesia is no longer in effect.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.

      Igor Lončarević

      Partner, Head of Tax & Legal

      KPMG in Serbia and in Montenegro

      Biljana Bujić

      Partner, Tax & Legal

      KPMG in Serbia and in Montenegro


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      Double Taxation Treaties – Situation as at 1 January 2019

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      The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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