Serbia - The Construction Permanent Establishment under Serbian Domestic and Tax Treaty Law
- G. Ilić-Popov; S.V. Kostić
- European Taxation, 2013 (Volume 53), No 6
- 7 May 2013
This article addresses the construction PE definition under Serbian domestic law and the 49 tax treaties currently applied by Serbia. Through a comparison of both legal instruments, the authors attempt to determine the criterion for subjecting construction activities of non-residents to Serbian tax jurisdiction, placing particular attention on practical issues facing both taxpayers and the Serbian tax authorities in applying domestic law, as well as tax treaty construction PE norms.