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Key Points of Tax Convention with Serbia

Japanese

[Provisional translation]

1. Taxation on Business Profits

Where an enterprise of one of the two countries has in the other country a permanent establishment (such as a branch) through which the enterprise carries on business, only the profits attributable to the permanent establishment may be taxed in that other country. 

2. Taxation on Investment Income

Taxation on investment income (dividends, interest and royalties) in the source country will be subjected to the maximum rates or exempted as follows:

投資所得(配当、利子及び使用料)
Dividends5% (holding for 365 days at least 25% of: 
       where paid by a company of Japan, voting power;
       where paid by a company of Serbia, capital.)
10% (others)
InterestExempted (received by the Governments, etc.)
10% (others)
Royalties5% (copyright)
10%(others)

3. Prevention of Abuse of the Convention

In order to prevent abuse of benefits under the Convention, any benefit under the Convention will not be granted if it is reasonable to conclude that obtaining such a benefit was one of the principal purposes of any transaction, or if the income is attributable to a permanent establishment in a third country and does not satisfy specified conditions. 

4. Mutual Agreement Procedure

Taxation not in accordance with the provisions of the Convention may be resolved by mutual agreement between the tax authorities of the two countries. 

5. Exchange of Information

In order to effectively prevent international tax evasion and tax avoidance, the exchange of information concerning tax matters between the two countries are introduced.