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Serbia Cross-Border Tax Guide 2026

Serbia's cross-border tax rules include withholding taxes of 20% on outward payments of dividends, interest, and royalties, with significant relief under EU/FATF provisions and over 65 double tax treaties. Transfer pricing rules follow OECD guidelines.

Overview — Cross-Border Taxation

Cross-border taxation in Serbia is governed by domestic law and Serbia's extensive network of double tax treaties (DTTs). As an EU candidate country, Serbia has aligned many of its cross-border tax rules with EU standards, including the EU/FATF exemption for dividend and interest WHT.

Withholding Tax Rates

Payments to non-residents are subject to WHT at the following rates, subject to DTT relief:

  • Dividends: 20% standard, 0% for EU/FATF residents, 0% under most DTTs
  • Interest: 20% standard, 0% for EU residents, 0% under most DTTs
  • Royalties: 20% standard, 0-10% under DTTs

Double Tax Treaty Network

Serbia has over 65 DTTs, making it one of the best-connected treaty networks in the region. Key treaty partners include:

  • All EU member states (Germany, France, Italy, Austria, Hungary, Romania, etc.)
  • United States
  • Canada
  • China
  • India
  • Russia
  • UAE
  • Turkey
  • Switzerland, Norway, Kuwait, Qatar, and many more

Treaties generally follow the OECD Model Convention and provide reduced WHT rates on dividends (5-15%), interest (0-10%), and royalties (0-10%).

Transfer Pricing

Serbia's transfer pricing rules are based on OECD Transfer Pricing Guidelines. Key requirements:

  • Related-party transactions must be conducted at arm's length
  • Documentation must be prepared and maintained (master file, local file, country-by-country reporting for large groups)
  • Advance pricing agreements (APAs) are available
  • Penalties apply for non-compliance with documentation requirements

Controlled Foreign Company (CFC) Rules

Serbia has CFC rules that may attribute income of a foreign controlled entity to a Serbian resident taxpayer if the foreign entity is subject to an effective tax rate significantly lower than the Serbian CIT rate (15%).

FAQs

What is the WHT rate on dividends paid to foreign shareholders?

The standard rate is 20%, but this is reduced to 0% for EU/FATF residents and under most DTTs.

Does Serbia have transfer pricing rules?

Yes, Serbia follows OECD Guidelines. Related-party transactions require arm's length pricing and supporting documentation.

How many DTTs does Serbia have?

Serbia has over 65 double tax treaties in force, covering most major economies worldwide.

Disclaimer

This guide provides general information about Serbian cross-border tax rules for 2026. Tax laws and treaties are subject to change. Always consult with a qualified Serbian tax advisor. InvestmentKit does not provide tax advice.