Serbia & Malta Double Tax Treaty


The Double Taxation Relief Treaty between Malta and Serbia was signed in Valletta on 9 September 2009 and is currently in force since 16 June 2010. The main features of the Double Tax Treaty Malta Serbia are as follows:

Serbian Withholding Taxes

Dividend Income

The Double Tax Treaty Malta Serbia states that the maximum Serbian withholding tax on dividends distributed by a Serbian resident company to a Maltese resident company where the Maltese resident company holds at least 25% of the share capital of the Serbian resident company is 5%. In all other cases, the maximum Serbian withholding tax is 10%.

Interest Income

The Double Tax Treaty Malta Serbia states that no Serbian withholding tax is charged on interest paid by a Serbian resident to a Maltese resident owner of the interest income.

Royalty Income

The Double Tax Treaty Malta Serbia sets out a maximum Serbian withholding tax of: - 5% on royalties paid for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films or films or tapes used for radio or television broadcasting). - 10% on royalties paid for the use of, or the right to use, any patent, trademark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience by a Serbian resident to a Maltese resident beneficial owner of the royalty income.

Other Income

The Double Tax Treaty Malta Serbia states that pensions and other similar remuneration from Serbian sources to a Maltese resident individual may only be taxed in Malta.

However, this does not apply for pensions paid by the Serbian state or a political subdivision or a local authority thereof, which are taxable in Serbia only.

Please contact us should you require any more information on the Malta Serbia Double Tax Treaty and the unique tax planning opportunities that may arise. You can email us on enquiries@papilioservices.com or call us directly on +356 2258 2000.


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