Bosnia and Herzegovina

FBiH WHT

WHT in the Federation of Bosnia and Herzegovina is calculated on income generated by a non-resident through performance of occasional business activity in the territory of the Federation of Bosnia and Herzegovina. WHT is due on payment or any other settlement of the following:

• Dividends (i.e. shares in profit).
• Interest or the functional equivalent to interest.
• Royalties and intellectual property (IP) rights.
• Fees for management, technical, and educational services (including fees for market research, tax consulting, audit services, and consulting services).
• Compensations for lease of movable and immovable property.
• Compensation for fun and sport events.
• Insurance or reinsurance premiums from risks in the Federation of Bosnia and Herzegovina.
• Compensation for telecommunication services.
• Other service fees, but only for non-residents from the countries that do not have a signed DTT with Bosnia and Herzegovina.

WHT shall be paid at the rate of 5% on dividend payments and 10% for interest, royalties, and other, if not reduced under a tax treaty.

RS WHT

As per the CIT Law of Republika Srpska, WHT in Republika Srpska is due on the following income payments to a foreign legal entity:

• Payment of dividends and shares in profit.
• Payment of interest.
• Payment of royalties and other payments for IP rights.
• Payment for performance of entertainment, art, or sports program in Republika Srpska.
• Payment for professional, scientific, technical, and educational services (market research, advertising and promotion, management, consulting, tax and business consulting, services of auditors, accountants, lawyers, education, and other similar services).
• Payments for market research, advertising and promotion, management, consulting, tax and business consulting, and services of auditors, accountants, and lawyers.
• Payments for insurance and reinsurance premiums in Republika Srpska.
• Payments for telecommunication services between Republika Srpska and another country.
• Payments for lease of movable property.

WHT is also due on the income from services that is paid by a resident of Republika Srpska to a resident of a country that has not concluded a DTT with Bosnia and Herzegovina. WHT is also due in case that income subject to WHT is settled to a non-resident in some other way.

The WHT rate in Republika Srpska is 10%.

BD WHT

Any legal or physical person from Brčko District, as well as any non-resident legal or physical person with PE in Brčko District, who pays revenue to a non-resident legal person is to withhold tax from the total payment of revenue and is to remit the withheld tax to the Public Revenues Account of Brčko District.

The WHT applies to the following revenue payments, regardless of whether the revenue is received in Brčko District or abroad:

• Payment of interest or its functional equivalent under financial instruments and arrangements from a resident.
• Payment for entertainment or sporting activities carried out in Brčko District, regardless of whether the revenue is received by the entertainer or sportsman or by another person.
• Payment for the performance of management, consulting, financial, technical, or administrative services if the revenue is from a resident or if the revenue is paid by or included in the books and records of a PE in Brčko District or if such payment is deducted for the purpose of determining the tax base.
• Payment in the form of insurance premiums for the insuring or reinsuring of risks in Brčko District.
• Payment for telecommunication services between Brčko District and a foreign state.
• Payment of royalties.
• Payment of lease for movable property.
• Payment for the performance of other services in Brčko District.

WHT is not due on dividend payments.

The WHT rate in Brčko District is 10%.

WHT rates based on available DTTs

Notes

1. The lower rate applies if the beneficial owner is a company (other than a partnership) that directly holds at least 25% of the capital of the company paying the dividends.
2. The lower rate applies if the beneficial owner is a company (other than a partnership) that directly holds at least 20% of the capital of the company paying the dividends.
3. The lower rates apply if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends. The competent authorities of the contracting state shall, by mutual agreement, settle the mode of application of these concessions.