Serbia Tax Residency Guide 2026

Overview — Tax Residency Rules

Serbia's tax residency rules determine whether an individual is subject to taxation on worldwide income (resident) or only Serbian-source income (non-resident). The rules follow international norms and are supported by over 65 double tax treaties (DTTs) that provide tie-breaker provisions for dual-residency situations.

Primary Test — 183 Days

An individual is considered a Serbian tax resident if they are physically present in Serbia for 183 days or more in any 12-month period. This is the primary test and applies to both Serbian nationals and foreigners. Days of arrival and departure generally count toward the 183-day count.

Secondary Test — Centre of Vital Interests

Even if the 183-day test is not met, an individual may be considered resident if they have a permanent home in Serbia and their centre of vital interests (personal and economic relations) is in Serbia. Factors considered include:

• Location of permanent home and family residence
• Place of employment and business operations
• Location of significant assets and bank accounts
• Social and cultural ties (club memberships, associations)

Double Tax Treaty Network — 65+ Treaties

Serbia has one of the most extensive DTT networks in Southeast Europe, with over 65 treaties in force. Key treaty partners include:

• EU: All EU member states (Germany, France, Italy, Austria, Romania, Hungary, etc.)
• North America: United States, Canada
• Asia: China, India, UAE, Turkey, Russia, Kazakhstan, Azerbaijan
• Other: Switzerland, Norway, Kuwait, Qatar, Egypt

These treaties typically follow the OECD Model Tax Convention and provide reduced WHT rates on dividends, interest, and royalties, as well as tie-breaker rules for dual residents.

Residency for Companies

A company is considered a Serbian tax resident if it is incorporated under Serbian law or has its place of effective management in Serbia. Resident companies are taxed on worldwide income. Non-resident companies are taxed only on Serbian-source income.

FAQs

How many days qualify for tax residency?

183 days or more in any 12-month period. Alternatively, having a permanent home and centre of vital interests in Serbia can also establish residency.

Does Serbia have DTTs with major economies?

Yes, Serbia has over 65 DTTs including with the US, Canada, China, India, UAE, Russia, Turkey, and all EU member states.

What happens if I'm resident in two countries?

Dual residency is resolved through the tie-breaker provisions in the applicable DTT, typically based on the individual's permanent home, centre of vital interests, habitual abode, and nationality.

Disclaimer

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