Corporate - Corporate residence

Last reviewed - 01 April 2024

A legal entity is considered to be a resident of Serbia if it is established or has its place of effective management and control in Serbia.

Permanent establishment (PE)

A PE is any permanent place of business through which a non-resident conducts its business.


  1. Branch, 
  2. Plant,
  3. Representative office,
  4. A place of production, a factory or a workshop,
  5. A mine, an oil or gas well, a quarry or any other place of extraction of natural


A PE includes a permanent or mobile construction site, construction or assembly works, if they last longer than six months, namely: 

  1. one or several construction or mounting projects executed concurrently: or, 
  2. several constructions or assemblies that are performed without interruption one after the other.

If a person, while representing a non-resident taxpayer, has the authority to conclude contracts on behalf of that taxpayer and exercises such authority, it shall be deemed that the non-resident taxpayer has a permanent establishment with regard to the operations performed by the representative on behalf of the taxpayer.

A permanent establishment shall not exist if the non-resident taxpayer conducts its business through a commissioner, broker or any other person which in the conduct of its own business acts in its own name, but for the others account.

Neither shall the following make up a permanent establishment:

  1. Keeping stocks of goods or materials belonging to a non-resident taxpayer exclusively for purposes relating to storage, presentation or delivery, or using premises intended for such purposes exclusively;
  2. Keeping stocks of goods or materials belonging to a non-resident taxpayer exclusively for the purpose of their being processed in another enterprise or by a sole trader;
  3. Keeping a permanent place of business exclusively for the purpose of procuring goods or collecting information for the needs of a non-resident taxpayer or for the purpose of engaging in any other activity of preparatory or auxiliary for the needs of a non-resident taxpayer.