A Protocol between the Government of the Republic of Serbia and the Swiss Federal Council was signed in Belgrade on 19. September 2023, amending the Agreement on the Avoidance of Double Taxation from 2005, which was originally concluded between the Council of Ministers of Serbia and Montenegro and the Swiss Federal Council. Since both Serbia and Switzerland are signatories to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, which relates to double taxation avoidance agreements, it was necessary to align the existing Agreement with the Convention’s standards.
This Protocol has achieved that alignment, not only adapting the text of the Agreement to the new standards concerning cross-border taxation but also improving and clarifying provisions related to corporate taxation, taxation of associated enterprises, capital gains, and the exchange of information between government authorities.
The Protocol is expected to come into effect on 01. January 2024.