By entering into bilateral agreements on avoidance of double taxation, in order to properly apply all provisions in the agreement countries are trying to determine the rules on taxation of income and property, i.e. if the agreement provides taxation rights to source country or country of residence.
Serbia has concluded 59 bilateral agreements on avoidance of double taxation where we also include the agreement concluded with Israel in November 2018.
Within these 59 agreements, only three of them (until Switzerland introduces WHT on royalties paid to non-residents) are stipulating that royalty income will not be taxed in Serbia if royalty income is realized by residents of other contracting states. In other words, if tax residents of France, Sweden or Switzerland generate royalty income in Serbia, exclusive right of taxation of such income is given to the country of residence in line with internal taxation rules.