The tax treaty has been signed between Canada and the Republic of Serbia.  Finance Canada mentions that the withholding rate for dividends for associated companies will be 5% and 15% in all other cases.

One interesting note in the treaty is that residence for “other than an individual” (i.e. a corporation) will be decided by the competent authorities looking at effective management and control as well as incorporation place and other relevant criteria.  And, if the competent authorities have not made a decision, no treaty benefits will be given.

You can find a copy of the announcement and tax treaty here.

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