Serbian cross-border tax for tax year 2026. Covers tax residence of individuals (domicile, centre of business and vital interests, the 183-day test, arrival and departure in the year) and of companies (incorporation or place of effective management); how non-resident individuals and companies are…
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Accountant-authored. Written and published by Ryan Duguid, an accountant approved on OpenAccountants. Their licence number is not on file. Their registration is in Australia; this skill covers Serbia. General reference material, not advice on your specific facts; don't file, pay, or take a position on it without a professional reviewing your situation.
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| Item | Rate or amount | Tax year | Source |
|---|---|---|---|
| Individual residence: days test | 183 days or more in any 12-month period starting or ending in the tax year | 2026 | ZPDG Art. 7(2) |
| Non-resident individual, short stay exemption | Income exempt if in Serbia no more than 90 days in a 12-month period and paid by a non-resident principal with no Serbian activity (or whose Serbian activity the service does not serve) | 2026 | ZPDG Art. 9b |
| Individual: dividends and interest paid by a Serbian legal entity | 15% of gross | 2026 | ZPDG Arts. 63 and 64 |
| Individual: interest on dinar savings deposits and on Serbian government, provincial, municipal or NBS debt securities | Exempt | 2026 | ZPDG Art. 65 |
| Individual: rent from Serbian immovable property | 20% of gross less 25% standard costs (or actual costs on request) | 2026 | ZPDG Arts. 65v and 65g |
| Individual: royalties (copyright, related rights, industrial property) | 20%, after standard costs of 50%, 43% or 34% of gross for authors by type of work; actual listed costs for industrial property | 2026 | ZPDG Arts. 56 to 58 |
| Individual: other income (contract for work, board fees, other services) | 20% of gross less 20% standard costs | 2026 | ZPDG Arts. 85(3) and 86 |
| Individual: capital gains on Serbian real estate, shares, securities, IP | 15%; no gain if held 10 years or more without a break | 2026 | ZPDG Arts. 72a(1)(5), 76 and 77 |
| Company: dividends, royalties, interest, rent in Serbia, market research, accounting, audit, legal and business consulting | 20% withholding unless a treaty gives less | 2026 | ZPDPL Art. 40(1) |
| Company: performers' and sportsmen's fees not taxed as an individual's income | 20% withholding | 2026 | ZPDPL Art. 40(3) |
| Company on the preferential tax jurisdictions list: royalties, interest, rent and any service wherever performed | 25% withholding | 2026 | ZPDPL Art. 40(4) |
| Company on the list: dividends | 20% (Article 40(4) does not raise dividends) | 2026 | ZPDPL Art. 40(1) and (4) |
| Preferential tax jurisdictions list | 49 jurisdictions in force (51 entries, items 22 and 43 deleted) | 2026 | Rulebook, Sl. glasnik 122/12, 104/18, 161/20 |
| Company: capital gains on Serbian assets | 20% by assessment unless a treaty says otherwise; return within 30 days through a tax proxy | 2026 | ZPDPL Art. 40(7) and (10) |
| Withholding on payments to secondary raw materials and waste sellers | 1% (2026 only; repealed from 1 January 2027) | 2026 | ZPDPL Art. 40(15); see rs-corporate-tax |
| Corporate foreign withholding credit cap (Art. 53a) | Credit up to 15% of 40% of the grossed-up foreign income | 2026 | ZPDPL Art. 53a(3) |
| Newly settled employee: tax base reduction | 70% of salary from a qualifying employer, for 5 years | 2026 | ZPDG Art. 15v |
| Newly settled employee: monthly salary floor | Over RSD 439,692 (general case); over RSD 293,128 (under 40, returned from study abroad) | 2026 (Sl. glasnik 115/2025) | ZPDG Art. 15v(5) and (6) |
| Late payment interest | NBS reference rate plus 10 percentage points, simple interest | 2026 | ZPPPA Art. 75 |
Source-cited draft: not reviewed by an accountant, not for filing.
This skill is the cross-border hub of the Serbia pack. It says who Serbia taxes and on what, what a Serbian payer must withhold when money goes to a non-resident, how treaty relief is claimed, and what changes on arrival and departure. It links to the other Serbia skills for the detail and does not repeat them:
Statutes used, all as Ministry of Finance consolidated texts read on 23 October 2026:
Individuals: resident or not (ZPDG Article 7). An individual is a Serbian resident if either test is met:
Three more rules from Article 7:
A resident is taxed on worldwide income (Article 7(1)). A non-resident is taxed only on income earned in Serbia (Article 8(1)). That includes, in particular, income from work done in Serbia and from using or disposing of a right in Serbia (Article 8(2)).
Companies (ZPDPL Articles 2 and 3). A legal entity is resident if it is incorporated in Serbia or has its place of effective management and control there. A resident is taxed on worldwide profit. A non-resident company is taxed on profit from a permanent establishment in Serbia, unless a treaty says otherwise. Without a PE it is taxed by withholding or by assessment on certain Serbian income (Article 40).
Permanent establishment (ZPDPL Article 4).
Who must withhold. The withholding agent is the payer:
If the payer is not a withholding agent, for example a private individual or a foreign employer, the recipient self-assesses (ZPDG Article 100a).
| Item | Rate or amount | Tax year | Source |
|---|---|---|---|
| Individual residence: days test | 183 days or more in any 12-month period starting or ending in the tax year | 2026 | ZPDG Art. 7(2) |
| Non-resident individual, short stay exemption | Income exempt if in Serbia no more than 90 days in a 12-month period and paid by a non-resident principal with no Serbian activity (or whose Serbian activity the service does not serve) | 2026 | ZPDG Art. 9b |
| Individual: dividends and interest paid by a Serbian legal entity | 15% of gross | 2026 | ZPDG Arts. 63 and 64 |
| Individual: interest on dinar savings deposits and on Serbian government, provincial, municipal or NBS debt securities | Exempt | 2026 | ZPDG Art. 65 |
| Individual: rent from Serbian immovable property | 20% of gross less 25% standard costs (or actual costs on request) | 2026 | ZPDG Arts. 65v and 65g |
| Individual: royalties (copyright, related rights, industrial property) | 20%, after standard costs of 50%, 43% or 34% of gross for authors by type of work; actual listed costs for industrial property | 2026 | ZPDG Arts. 56 to 58 |
| Individual: other income (contract for work, board fees, other services) | 20% of gross less 20% standard costs | 2026 | ZPDG Arts. 85(3) and 86 |
| Individual: capital gains on Serbian real estate, shares, securities, IP | 15%; no gain if held 10 years or more without a break | 2026 | ZPDG Arts. 72a(1)(5), 76 and 77 |
| Company: dividends, royalties, interest, rent in Serbia, market research, accounting, audit, legal and business consulting | 20% withholding unless a treaty gives less | 2026 | ZPDPL Art. 40(1) |
| Company: performers' and sportsmen's fees not taxed as an individual's income | 20% withholding | 2026 | ZPDPL Art. 40(3) |
| Company on the preferential tax jurisdictions list: royalties, interest, rent and any service wherever performed | 25% withholding | 2026 | ZPDPL Art. 40(4) |
| Company on the list: dividends | 20% (Article 40(4) does not raise dividends) | 2026 | ZPDPL Art. 40(1) and (4) |
| Preferential tax jurisdictions list | 49 jurisdictions in force (51 entries, items 22 and 43 deleted) | 2026 | Rulebook, Sl. glasnik 122/12, 104/18, 161/20 |
| Company: capital gains on Serbian assets | 20% by assessment unless a treaty says otherwise; return within 30 days through a tax proxy | 2026 | ZPDPL Art. 40(7) and (10) |
| Withholding on payments to secondary raw materials and waste sellers | 1% (2026 only; repealed from 1 January 2027) | 2026 | ZPDPL Art. 40(15); see rs-corporate-tax |
| Corporate foreign withholding credit cap (Art. 53a) | Credit up to 15% of 40% of the grossed-up foreign income | 2026 | ZPDPL Art. 53a(3) |
| Newly settled employee: tax base reduction | 70% of salary from a qualifying employer, for 5 years | 2026 | ZPDG Art. 15v |
| Newly settled employee: monthly salary floor | Over RSD 439,692 (general case); over RSD 293,128 (under 40, returned from study abroad) | 2026 (Sl. glasnik 115/2025) | ZPDG Art. 15v(5) and (6) |
| Late payment interest | NBS reference rate plus 10 percentage points, simple interest | 2026 | ZPPPA Art. 75 |
The ZPDG has no higher rate for individuals resident in a preferential tax jurisdiction. The 25% rate is only in the ZPDPL and only for companies.
Non-resident individuals. The base is each Serbian-source payment, taxed by schedule. Withholding is final for most items. The payer applies the standard costs shown above and withholds at the schedule rate (ZPDG Articles 99 and 101).
Non-resident companies. The base for withholding is the gross amount paid (ZPDPL Article 40(1)). There is no deduction for costs. For capital gains the base is the gain computed under Articles 27 to 29.
When a listed jurisdiction does not count (ZPDPL Article 3a). A non-resident company counts as from a preferential jurisdiction if it is incorporated there, has its registered seat or seat of management there, or has its place of effective management there. The rule does not apply if the company is a resident of a state that has a tax treaty with Serbia, for that treaty's purposes (Article 3a(3)).
Payments to a Serbian PE. No withholding applies to payments to a Serbian PE of a non-resident company (Article 40(12)). The exception is a PE of a company from a preferential jurisdiction. For that PE, the payer withholds on dividends at 20% and on royalties, interest, rent and services at 25%. Those items then stay out of the PE's tax base (Article 40(13) and (14)).
Foreign tax credit, individuals (ZPDG Article 12). A resident who pays tax abroad on foreign income gets a credit. It is capped at the Serbian tax on that income under the ZPDG.
Foreign tax credit, companies.
Newly settled employees (ZPDG Article 15v). A person who moves to Serbia and becomes resident can have 70% of their salary from a qualifying employer left out of the salary tax base, for five years from the employment contract. The job must be an indefinite-term employment contract. The person must settle in Serbia when or soon after starting, and be resident on the centre of vital interests test and for treaty purposes (Article 15v(1) and (7)). Two groups qualify:
The employer must be a Serbian resident. It must not be related to the person's previous employer, with one exception in Article 15v(3) for people who were Serbian residents for at least three years since 1990. Payroll mechanics are in serbia-payroll.
Claiming treaty relief at source. The payer may apply the treaty rate when it pays (ZPDG Article 107a; ZPDPL Article 40a). Two conditions:
If the payer does not hold the certificate when it pays, it withholds at the domestic rate. A certificate supplied later turns the difference into overpaid tax, which the non-resident can reclaim (ZPDG Article 107a(5) and (6); ZPDPL Article 40a(6) and (7)). On request, the Tax Administration certifies the tax paid in Serbia, so the recipient can claim a credit at home (Article 107a(4); Article 40a(4)).
Treaties in force. The Ministry of Finance lists Serbia's treaties, many as combined texts with the Multilateral Convention (MLI), at https://www.mfin.gov.rs/propisi/ugovori-o-izbegavanju-dvostrukog-oporezivanja. The rate for a given payment and the tie-breaker for a dual resident come from the treaty, not from domestic law. Read the treaty for the recipient's state before applying a reduced rate.
Preferential list in practice. Check the recipient's state against the 49 entries in force before every payment of royalties, interest, rent or service fees. The list includes Andorra, Bahamas, Bahrain, Bermuda, the British Virgin Islands, the Cayman Islands, Gibraltar, Guernsey, the Isle of Man, Jersey, Liechtenstein, Mauritius, Monaco, Panama, Seychelles and others. Check the Article 3a(3) treaty carve-out against the treaty list.
Leaving Serbia. A person who leaves for good and is not resident in the following year is not resident for the rest of the year of departure, if they no longer have a domicile or centre of vital interests in Serbia in that period (ZPDG Article 7(6)). From then on, only Serbian-source income is taxed. The ZPDG has no exit tax or deemed sale on departure. Points to settle on departure:
For companies, the ZPDPL text that applies to 2026 (amendments up to 94/2024) has no exit tax and no CFC rules. Law 80/2026 adds both (Articles 62b and 62g of the new text), but not for 2026; see rs-corporate-tax for their start date.
Anna lives in Germany and is not a Serbian resident. She owns an office in Novi Sad and rents it to a Serbian d.o.o. for RSD 100,000 a month, RSD 1,200,000 for 2026. The tenant is a legal entity, so it withholds (ZPDG Article 99(1)(4)). The taxable amount is the gross rent less 25% standard costs (Article 65v): 1,200,000 × 0.75 = RSD 900,000. Tax at 20% (Article 65g) is RSD 180,000, which is 15% of the gross rent. Anna receives RSD 1,020,000.
The tenant files a PPP-PD and pays the tax with each monthly payment. Monthly, that is RSD 15,000 of tax on RSD 100,000. Germany is on the Ministry of Finance treaty list. Under the Serbia-Germany treaty (the Yugoslavia-Germany treaty signed in Bonn on 26 March 1987), Serbia may tax income from immovable property situated in Serbia, including rent (Article 6(1) and (3)). Germany then exempts that income from German tax and may take it into account for the rate (Article 24(1)(a)). The treaty gives exemption here, not a credit for the Serbian tax. The tenant must give Anna a certificate of the tax withheld by 31 January 2027 (ZPPPA Article 41(11)), which is her proof of the Serbian tax.
name: Example 1, non-resident individual, rent from a Serbian company, 2026
inputs:
monthly_rent: 100000
months: 12
steps:
- gross_rent: monthly_rent * months
- standard_costs: gross_rent * 0.25
- taxable: gross_rent - standard_costs
- tax: taxable * 0.20
- net_received: gross_rent - tax
- monthly_tax: tax / months
expected:
gross_rent: 1200000
taxable: 900000
tax: 180000
net_received: 1020000
monthly_tax: 15000
Sava d.o.o., a Belgrade company, makes four payments in 2026:
Panama is on the preferential list, and Panama does not appear on the Ministry of Finance treaty list, so the Article 3a(3) carve-out does not help.
Total withholding is RSD 2,700,000. Sava files a PDPO/S return within three days of each payment.
name: Example 2, outbound payments to a preferential jurisdiction and to an Irish agency, 2026
inputs:
consulting_panama: 4000000
advertising_panama: 2000000
dividend_panama: 6000000
advertising_ireland: 2000000
steps:
- wht_consulting: consulting_panama * 0.25
- wht_advertising_panama: advertising_panama * 0.25
- wht_dividend: dividend_panama * 0.20
- wht_advertising_ireland: advertising_ireland * 0
- total_wht: wht_consulting + wht_advertising_panama + wht_dividend + wht_advertising_ireland
expected:
wht_consulting: 1000000
wht_advertising_panama: 500000
wht_dividend: 1200000
wht_advertising_ireland: 0
total_wht: 2700000
Not yet confirmed: the 2026 average annual salary that sets the non-resident annual tax threshold (published after year end); the current NBS reference rate used for late payment interest; whether the Ministry of Finance treaty page shows every treaty in force (it may not list all of them), and so whether a given listed jurisdiction falls under the Article 3a(3) carve-out; the form code of the Serbian residence certificate under the Minister's rulebook; how social contributions apply to a non-resident's contract income (left to serbia-social-contributions).
Contributed by Ryan Duguid.
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