Singapore and Serbia Sign Avoidance of Double Taxation Agreement

04/05/2021
Singapore and Serbia Sign DTA

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 summary of the key terms in the Singapore-Serbia DTA is as follows:

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

 

The DTA does not have the force of law until it has been ratified by both countries. The full text of the DTA is available on the Inland Revenue Authority of Singapore’s website here

Source: Inland Revenue Authority of Singapore