Double taxation Russia-Serbia

Double taxation between Russia and Serbia is regulated by an intergovernmental agreement that determines in which country a resident must pay income taxes. In 2026 the updated version of the 1995 agreement with the 2021 amendments is in force, clarifying residency rules and the allocation of the tax base. Below are the key points: how residency is defined, where to pay taxes on salary, dividends, rent and other types of income, and the procedure for confirming status.

How residency is determined under the Russia-Serbia agreement

According to article 4 of the agreement, a person is considered a resident if they:

• permanently reside in one of the countries for more than 183 days in a calendar year;
• have a centre of vital interests (main home, family, business);
• are registered as a tax resident (in Russia - by place of registration or tax registration, in Serbia - by place of permanent residence or registration with the tax authority);
• are a citizen of the country (if the first three criteria are not met).

If a person is recognised as a resident of both countries, the "permanent place of residence" test is applied. For example, a Russian who moves to Serbia permanently becomes a Serbian resident from the first day of residence unless they prove otherwise. The status is confirmed through automated information-exchange systems (in Russia - the FNS, in Serbia - the PIT).

Salary taxes: where to pay and how to avoid double withholding

Article 15 of the agreement states that tax is paid where the work is performed. If the employee:

• works in one country but receives salary from an employer in the other country (e.g., remote work for a Serbian company from Russia), tax is withheld in the country where the work is actually performed;
• is a resident of Serbia and works remotely for a Russian company, tax is withheld in Serbia at a rate of 10-20 % (depending on income).

Personal income tax rates in Serbia in 2026:

Annual income	Rate
up to 12 000 EUR	10 %
12 001 - 36 000 EUR	20 %
over 36 000 EUR	25 %

In Russia the salary tax is 13 % for residents and 30 % for non-residents. When tax is paid in one country, a repeat tax in the other is not levied, but proof of payment (tax residency certificate) is required.

Taxes on dividends, interest and royalties

The agreement sets maximum rates:

• Dividends - 5 % (if the recipient holds ≥ 25 % of the charter capital) or 10 % otherwise;
• Interest - 5 % (if the creditor is a bank or the state) or 10 % otherwise;
• Royalties - 5 % (if the author is a resident of one of the countries).

Example: a Russian receives dividends from a Serbian company, 10 % is withheld in Serbia, then 3 % in Russia (with confirmed residency). The total rate does not exceed 13 %. To apply the benefit a residency certificate is needed - in Serbia it is issued free of charge by the local tax office, in Russia - by the FNS.

Taxation of rental income

If a Russian rents out an apartment in Serbia, tax is paid where the property is located:

• Rental income tax - 20 % (rate for individuals in 2026);
• VAT does not apply if the landlord is an individual (exemption under article 22 of the Serbian Tax Code);
• Property tax - 0.4 % of the cadastral value if the value > 100 000 EUR.

In Russia rental tax is 13 % for residents and 30 % for non-residents. When tax is paid in Serbia it can be credited in the Russian declaration (deduction up to 13 % of the amount paid abroad).

How to confirm residency status

To avoid double taxation a residency certificate is required:

• Serbia: submit an application to the local PIT (Poreska uprava) branch with passport, proof of residence (rental agreement or municipal extract) and a tax return. Processing time - 5-10 working days, cost - free.
• Russia: obtain the certificate from the FNS at the place of registration (via personal account or in person). Processing time - 5 days, state fee - 0 EUR.

If one tax authority does not recognise the certificate, a mutual agreement (Mutual Agreement Procedure, MAP) can be initiated through the tax administrations of both countries. The procedure takes 6-12 months and is free of charge.

Practical cases

Case 1. Remote work for a Serbian company
A Russian citizen moved to Serbia in January 2026 but continues to work remotely for a Russian company. Salary tax is paid in Serbia at 10-20 % (depending on income). Russia does not withhold tax, but the income and paid tax must be reported in the Russian declaration.

Case 2. Dividends from a Serbian business
A Russian owns 30 % of a Serbian DOO and receives 50 000 EUR in dividends. Serbia withholds 10 % (5 000 EUR), Russia 3 % (1 500 EUR) after residency confirmation. Total 6 500 EUR (13 %).

Case 3. Renting an apartment in Belgrade
A Russian rents out a flat for 1 500 EUR per month (annual income 18 000 EUR). Serbian tax 20 % → 3 600 EUR. No tax is paid in Russia, but the income is declared; the credit is 13 % of 3 600 EUR = 468 EUR.

What changed in 2026

• Dividends: if the share in a company exceeds 10 % (previously 25 %), the rate drops to 5 %;
• Digital nomads: income from remote work for foreign companies is taxed in Serbia at 10 % (previously 20 %);
• Rent: from 2026 all rental agreements must be registered with PIT, otherwise tax is withheld at the maximum rate of 25 %.

Useful links

• How to obtain a residency certificate in Serbia
• Tax rates in Serbia in 2026 (official PIT website)
• Russia-Serbia double taxation avoidance agreement (Russian text)
• Tax calculator for individuals in Serbia (tax authority)