Singapore and Serbia Sign Avoidance of Double Taxation Agreement

03 May 2021

Singapore and Serbia have signed the Agreement between the Government of the Republic of Singapore and the Government of Republic of Serbia for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (“DTA”).
The DTA was signed by Minister for Education and Second Minister for Finance, Mr Lawrence Wong, and Minister of Finance for Serbia, Mr Siniša Mali.
The DTA clarifies the taxing rights of both countries on all forms of income flows arising from cross-border business activities, and minimises the double taxation of such income. This will lower barriers to cross-border investment and boost trade and economic flows between the two countries. Key terms of the Agreement can be found in the Annex.
The full text of the DTA is available on the Inland Revenue Authority of Singapore’s website here. The DTA will enter into force after ratification by both countries.

Ministry of Finance

Annex: Summary of key terms in the Singapore-Serbia DTA

Article in the DTA	Key terms in the DTA
Article 5, Permanent Establishment	Period test of 12 months for construction-related activities, beyond which residents of a contracting state could trigger a taxable presence in the other contracting state; Threshold of 270 days in any 12-month period for the furnishing of services by an enterprise of a contracting state within the other contracting state
Article 10, Dividends	5% withholding tax rate (if shareholding ≥ 25%); 10% withholding tax rate (all other cases)
Article 11, Interest	10% withholding tax rate
Article 12, Royalties	5% or 10% withholding tax rate depending on the nature of the royalties