As one of Serbia’s leading experts in matters of double taxation treaties (DTTs) Dejan Dabetić during September and October 2025, in the Head Office of the Serbian Tax Administration (STA) has given, a series of 5 (five) lectures, within the scope of the European Union’s project “EU support for Public Finance Management“, focusing on the Republic of Serbia’s role and achievements when it comes to DTTs.
Dejan’s lectures comes as a part of workshops that aim to support the development of the Republic of Serbia’s Tax Administration technical expertise in understanding and applying treaties on the avoidance of double taxation, which are crucial for fostering transparent and effective cross-border tax cooperation.
The Republic of Serbia currently applies treaties with 64 countries to avoid double taxation.
“The avoidance of international double taxation through solutions in bilateral treaties on the avoidance of double taxation concluded between contracting states relates to income tax for citizens, income tax for legal entities, as well as property tax in a static context”, said Dejan Dabetić.
He adds that the Republic of Serbia, from the perspective of the OECD and the UN, is among the countries that are gaining recognition for their, as he states, “not insignificant contribution to the further affirmation of the importance of DTTs.”
“For a state of the ‘calibre’ of the Republic of Serbia, the number of treaties on the avoidance of double taxation with 64 countries is commendable. It is important to note that DTTs are in force with our most significant foreign trade partners: out of the 27 EU members, DTTs are in force with 26 of them — Portugal is the only exception. Additionally, DTTs are in force with all the countries of the former SFRY, as well as with the so-called economic tigers of South and Southeast Asia: Singapore, Hong Kong, South Korea, along with India, the Russian Federation, the People’s Republic of China, Japan, Canada, some African countries, and the Middle East, among others,” says Dabetić.
In addition to 64 countries with which DTTs are in force , Dejan adds those where the DTT is not yet in force but is in various stages of negotiations: an exchange of the Draft Treaty has taken place; negotiations are ongoing; the DTT has been initialled, meaning discussions are happening about the date and location of signing; the DTT has been signed—its entry into force is anticipated—as well as the commencement of its application.
“When we consider all this, we are close to the number of 100 countries, which, in itself, supports the aforementioned recognition and respect of the Republic of Serbia, in terms of its presence on the international stage,” says Dabetić. He stresses that it is always possible to find a legal mechanism to prevent double taxation.
“This is achieved primarily by increasing the number of concluded DTTs, implementing the solutions outlined in their provisions, and raising awareness among taxpayers as well as the entire professional community about the economic benefits and significance of concluded DTTs. Supporting this, there is OECD data indicating that today, there are approximately 4,000 treaties worldwide on the avoidance of double taxation”, he says.
He, however, points out that in practice, double taxation often happens due to taxpayers’ insufficient knowledge of necessary conditions to realize all the benefits of existing DTTs.
“The existing solutions from DTTs are, for taxpayers, in many ways more favorable than the solutions from the domestic tax legislation of the contracting states that are applied in a situation when the DTT has not been concluded,” says expert Dabetić.
The topic, of course, cannot go without mentioning citizens of the Republic of Serbia who live and work abroad – either with or without their families.
For the purposes of applying the DTTs, citizens originally from the Republic of Serbia, who are colloquially called ‘gastarbeiters’, are considered tax residents of the countries they reside in, and not tax residents of the Republic of Serbia.
This means that these citizens, in their home country of tax residence (e.g., Germany), primarily pay tax, covering all income earned there as well as worldwide, including income earned in the Republic of Serbia, their country of origin and ancestral homeland.
The solutions contained in the DTTs enable citizens abroad to avoid double taxation in a situation where they, as tax residents of countries like Germany, earn income in the country of their non-residence or source of income (such as the Republic of Serbia). Consequently, they are subject to taxation both in their home country of residence (Germany) and in the country of their non-residence or source of income (Serbia).
Dejan Dabetić expects that the workshops with employees in the Tax Administration of the Republic of Serbia will help strengthen the capacity of STA and improve its readiness for quality interpretation and application of concluded DTTs.
