Double Tax Treaty with Vietnam

The Serbian Government ratified the Double Tax Treaty (DTT) signed with Vietnam. Subject to the pending document ratification by Vietnam, which is still expected this year, the agreement would enter into force on 1 January 2014.

Once valid, the new DTT between Serbia and Vietnam will provide for the following benefits to the beneficial owners of the respective type of income:

• Article 10 - Dividends:
  10% of the gross amount of the dividends, if the beneficial owner is a company (partnerships excluded) that holds directly at least 25% of the capital of the company paying the dividends
  15% of the gross amount of the dividends in all other cases 

• Article 11 - Interest:
  10% of the gross amount of the interest 

• Article 13 - Capital gain:
  0% if the investor sells equities issued by a company the assets of which, directly or indirectly, do not consist mainly of immovable property situated in Serbia - the standard tax rate would apply if this condition is not met 

Foreign investors that intend to benefit from DTT rates are obliged to provide a valid certificate of tax residence issued on the Serbian Ministry of Finance and Economy template.

Impact on investors: If Vietnam ratifies the agreement until the end of this year, in 2014 Serbia would be able to provide more favourable tax environment for investors from Vietnam.