DTT between Serbia and Israel

/in /by

The double taxation treaty between Serbia and Israel began to apply from 1.1.2020.

The taxes to which this Agreement applies are:

In Israel:

  • personal income tax and corporate income tax (including capital gains tax)
  • income tax on the alienation of property which is subject to taxation in accordance with the Law on Real Estate Taxation
  • tax that is prescribed in accordance with the Oil Profit Taxation Act.

In Serbia:

  • corporate income tax
  • personal income tax.

The maximum withholding tax rates stipulated by the Agreement are:

Dividends:

  • 5 percent of gross dividend if the beneficial owner is a company that, during the 365-day period, which includes the dividend payout date, directly owns at least 25 percent of the capital of the dividend-paying company
  • 15 percent of gross dividend in all other cases.

Interest:

  • 10 percent of gross interest
    Note: As an exception, interest accruing in Serbia to a resident of Israel shall be taxable only in Israel if the beneficial owner of the interest is the government of another Contracting State, its political subdivision, local government unit or the Central or National Bank. The reverse is also applicable.

Royalties:

  • 5 percent of the gross royalties (for the use or right of copyright in a literary, artistic or scientific work, including cinema films and films or films for television or radio) and
  • 10 percent of the gross amount of royalties (for use or for the right to use a patent, trademark, design or model, plan, secret formula or procedure, or for the use or right of use of industrial, commercial or scientific equipment or for notices relating to industrial , commercial or scientific experiences – expertise).