Serbia is one of the most underrated tax locations in Europe, with corporation tax of 15%, tax-free dividends between Serbian companies and double taxation agreements with countries including the United Kingdom. The decisive point for our clients: Serbia does not take part in the Common Reporting Standard (CRS), so account data is not passed automatically to tax authorities abroad.
Why Serbia for asset protection?
For holding companies, Serbia uses a credit system rather than an exemption. Dividends from a Serbian subsidiary remain tax-free for the Serbian parent company. Dividends from foreign subsidiaries are taxable, but Serbia credits the profits tax the subsidiary paid abroad, plus the foreign withholding tax. The condition: the holding company has held at least 10% for at least one year. If the dividend comes from a country with profits tax of 15% or more, there is practically nothing left to pay in Serbia. Gains from selling shareholdings, on the other hand, are taxed in full at 15% at holding level. Double taxation agreements exist with countries including the United Kingdom, where the 1981 convention with Yugoslavia still applies to Serbia. Serbia is not an EU member and does not take part in the Common Reporting Standard (CRS). This means that banks in Serbia do not report account data automatically to tax authorities abroad. For clients who want to hold an account outside the European exchange of information, Serbia is one of the closest and most practical options.
The tax framework
Corporation tax: 15%. Withholding tax on dividends paid to foreign companies: 20%, often less under a tax treaty. Dividends from foreign subsidiaries: taxable, with credit for the foreign tax from a 10% holding and a one-year holding period. Income tax: 10% on wages, 15% on dividends, interest and disposal gains. No wealth tax on financial assets. Inheritance tax: 0% for direct descendants, spouses and parents, 1.5% for siblings and their descendants, 2.5% for more distant or unrelated heirs.
Practical uses
Serbian structures are particularly suited to: an intermediate holding for shareholdings in Eastern Europe and the Balkans, managing licence income (withholding tax can be reduced under a tax treaty), holding property in the region, and as a basis for business owners looking for a location close to the EU but not bound by it.
Relevant services
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