Tax Alert, February 2020

As a reminder, Multilateral Convention has come into force for Serbia in October 2018 and is applicable as of 2019. Multilateral Convention amends the provisions of the existing bilateral Double Tax Treaties with the aim of preventing the erosion of the tax base, in case the Multilateral Convention has come into force for both contracting states which have notified the Double Tax Treaty under the Multinational Convention. The actual amendments to the provisions of a particular Double Tax Treaty depend on the choices of the both contracting parties.

In our tax alerts in the course of 2019, we have provided updates on the application of Multilateral Convention of Double Tax Treaties with Austria, UK, Ireland, Lithuania, Malta, Poland, Slovenia, Slovak Republic, France and Finland (synthesized text of these Double Tax Treaties is published in the Ministry of Finance website).

Below you may find further updates on the application of Multilateral Convention to certain Double Tax Treaties.

Belgium

Multilateral Convention has become effective for Belgium on 1 October 2019. Synthesized text is published in the Ministry of Finance website.
The provisions of Multilateral Convention have effect with respect to the Agreement, as follows:
- In Serbia and Belgium, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
- With respect to all other taxes levied by Serbia or Belgium, for taxes levied with respect to taxable periods beginning on or after 1 April 2020.

Georgia

Multilateral Convention has become effective for Georgia on 1 July 2019. Synthesized text is published in the Ministry of Finance website.
The provisions of Multilateral Convention have effect with respect to the Agreement, as follows:
- In Serbia and Georgia, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
- With respect to all other taxes levied by Serbia or Georgia, for taxes levied with respect to taxable periods beginning on or after 1 January 2020.

Denmark

Multilateral Convention has become effective for Denmark on 1 January 2020. Synthesized text has not yet been published in the Ministry of Finance website.
The provisions of Multilateral Convention have effect with respect to the Agreement, as follows:
- In Serbia and Denmark, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
- With respect to all other taxes levied by Serbia, for taxes levied with respect to taxable periods beginning on or after 1 July 2020;
- With respect to all other taxes levied by Denmark, for taxes levied with respect to taxable periods beginning on or after 1 January 2021.

India

Multilateral Convention has become effective for India on 1 October 2019. Synthesized text is published in the Ministry of Finance website.
The provisions of Multilateral Convention have effect with respect to the Agreement, as follows:
- In Serbia, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
- In India, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 October 2019;
- With respect to all other taxes levied by Serbia or India, for taxes levied with respect to taxable periods beginning on or after 1 April 2020.

Canada

Multilateral Convention has become effective for Canada on 1 December 2019. Synthesized text is published in the Ministry of Finance website.
The provisions of Multilateral Convention have effect with respect to the Agreement, as follows:
- In Serbia and Canada, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
- With respect to all other taxes levied by Serbia or Canada, for taxes levied with respect to taxable periods beginning on or after 1 June 2020.

Luxembourg

Multilateral Convention has become effective for Luxembourg on 1 August 2019. Synthesized text is published in the Ministry of Finance website.
The provisions of Multilateral Convention have effect with respect to the Agreement, as follows:
- In Serbia and Luxembourg, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
- With respect to all other taxes levied by Serbia or Luxembourg, for taxes levied with respect to taxable periods beginning on or after 1 February 2020.

Norway

Multilateral Convention has become effective for Norway on 1 November 2019. Synthesized text is published in the Ministry of Finance website.
The provisions of Multilateral Convention have effect with respect to the Agreement, as follows:
- In Serbia and Norway, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
- With respect to all other taxes levied by Serbia or Norway, for taxes levied with respect to taxable periods beginning on or after 1 May 2020.

United Arab Emirates

Multilateral Convention has become effective for UAE on 1 September 2019. Synthesized text is published in the Ministry of Finance website.
The provisions of Multilateral Convention have effect with respect to the Agreement, as follows:
- In Serbia and UAE, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
- With respect to all other taxes levied by Serbia or UAE, for taxes levied with respect to taxable periods beginning on or after 1 March 2020.

Ukraine

Multilateral Convention has become effective for Ukraine on 1 December 2019. Synthesized text is published in the Ministry of Finance website.
The provisions of Multilateral Convention have effect with respect to the Agreement, as follows:
- In Serbia and Ukraine, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
- With respect to all other taxes levied by Serbia or Ukraine, for taxes levied with respect to taxable periods beginning on or after 1 June 2020.

Netherlands

Multilateral Convention has become effective for Netherlands on 1 July 2019. Synthesized text is published in the Ministry of Finance website.
The provisions of Multilateral Convention have effect with respect to the Agreement, as follows:
- In Serbia and Netherlands, for taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
- With respect to all other taxes levied by Serbia or Netherlands, for taxes levied with respect to taxable periods beginning on or after 1 January 2020.

Other

It is expected that the Multilateral Convention will come into force for the following states with which Serbia has concluded double tax treaty:
1. Latvia – 1 February 2020
2. Qatar – 1 April 2020
3. Cyprus – 1 May 2020