Serbia: Protocol to Switzerland income tax treaty adopted by Parliament

It is expected that the protocol will enter into force 1 January 2025.

It is expected that the protocol will enter into force 1 January 2025.

The protocol to the Serbia-Switzerland income tax treaty was signed on 19 September 2023, adopted by the Serbian Parliament on 27 October 2023, and published in the official gazette on 31 October 2023.

It is expected that the protocol will enter into force 1 January 2025, assuming Serbia receives notice that Switzerland has completed its procedures for the protocol’s entry into force.

The protocol includes provisions relating to:

  • Easier international exchange of information, including bank secrecy information
  • Principle purpose of tax avoidance test
  • Application of Swiss rules on minimum taxation of groups of large multinational companies
  • Alienation of shares in limited liability companies subject to capital gain taxation
  • Deadline for a tax audit of profit attributed to a permanent establishment (PE)

Read an April 2024 report prepared by the KPMG member firm in Serbia



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