Convention Between the Government of the Republic of Serbia and the Government of Hong Kong Special Administrative Region of the People’s Republic of China (hereinafter: Hong Kong) For the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect To Taxes On Income and On Property (hereinafter: the Convention) entered into force on 30th December 2020 and began to apply in the Republic of Serbia on 1st January 2021.
The Convention was signed on 14th August 2020 in Belgrade and on 27th August 2020 in Hong Kong in the Serbian, Chinese and English languages.
Inside Hong Kong the Convention shall apply for each year of tax assessment starting on or after 1st April 2021.
The Agreement provides for the following preferential rates:
- 5% of the gross amount of dividends if the ultimate beneficial owner is a company which over a period of 365 days, including the date on which dividends are paid out, directly owns at least 25% of the capital of the company distributing the dividends;
- 10% of the gross amount of dividends in all other cases.
- 10% of the gross amount of interest.
Since Hong Kong is not a state but a special administrative region of China, there are exceptions.
- 5% of the gross amount of royalties (for using or the right to use a copyright for a literary, art or scientific work, including theatrical films and television or radio films or tapes);
- 10% of the gross amount of royalties (for using or the right to use a patent, trademark, design or model, plan, secret formula or procedure, or for using or the right to use industrial, commercial or scientific equipment, or for communications relating to industrial, commercial or scientific knowledge – know-how).