In the recent years Serbia, a country in the south-east of Europe, has been getting more and more popularity as a place of relocation and starting a business. The country’s good reputation is well-earned, because it is the place, where you can enjoy a European way of life, but at the same time escape the suffering of dealing with European Union’s bureaucracy or inflated real estate prices. Today, a lot of foreigners choose to get the Serbian passports, which opens doors to some unique opportunities this country has to offer.
Let us take a realistic look at the options that the Serbian Republic can offer and who exactly can enjoy them the most. Serbia is not a universal answer, and there are cases and circumstances, when we would not advise it. This country is for people with a taste for adventure, a bit of a less explored territory. If you have had a long stay in, say, Brazil or Argentina, and loved it, and now would like to do something similar with a European fleur to it, you will probably find yourself at home in Serbia.
At the same time, one should not expect this country to be something like the Eastern European Wild West. Far from it, when you find yourself on the tidy and green streets of the historical center, places like Vienna, Prague or Valencia inevitably come to mind. However, beyond the historical quarter of the capital, and especially out and about in the country one will find a great variety of more modern and less advanced architectural styles, and a unique, down-to-earth lifestyle.
Lately, the Serbian capital has been attracting investors and expats for several reasons. It is a direct flight away from the USA, Asia, and the Middle East. In addition, the immigration laws are more relaxed than in other European countries, so getting a residence permit or even a citizenship is more doable and affordable than in many of Serbia’s European neighbours. In addition, Serbia offers a well-organized offshore banking system and asset protection haven, which will later be discussed in more detail. Due to these and some other advantages, there has been a wave of investors (including crypto investors) and Digital Nomads floating into the country recently.
Another attractive feature in Serbia is very affordable real estate, especially if we consider property in the country. If you have always dreamed about owing a converted farm or starting a new label of wines made from your own vineyard, Serbia is definitely the place to make those dreams come true!
Historically, Belgrade was the capital of the former Yugoslavia and as such, a busy and important political, economic and cultural spot in the Balkans. The city has long gotten over the effects of the turmoil and the military operations of the 1990’s, and is now quite similar to the Eastern European capitals in its pace and vibes. The country is living with the thought of joining the EU quite soon: in March 2012 it was granted EU candidate status and, according to the estimates of the EU officials, can be expected to join the European Union around 2025.
However, for now the absence of EU membership is rather an advantage than a drawback. It gives Serbia more freedom and flexibility in dealing with expats willing to engage in economic activities here. The country is very business-friendly and very welcoming to foreign investments. If you are still interested in eventually getting an EU passport, your Serbian citizenship received today may provide the path to an EU passport by the time when you retire or perhaps when your children become of age.
Life in Serbia
The Serbs are said to have a unique sense of humour, which, of course, is best appreciated if you speak the local language. But even if you don’t, the local people will make you welcome as long as you don’t poke around too much into their private lives. And only if you put up with their smoking, which is allowed literally everywhere, and seems to be enjoyed by almost everyone! Although Serbs are generally social, it is a country where the “right to be left alone” is still very much respected as part of the culture.
Seriously speaking, Serbian people are quite friendly, warm and outgoing, and will enjoy a chance to practice their English. In Belgrade you will find many people who can carry on a conversation in it, and you will probably get by quite well speaking English in all situations.
Interestingly, the Serbian capital itself is in fact three cities! Budapest was formed in 1873 from the union of three cities – Buda, Pest, and Óbuda. However, people obviously didn’t care enough about the latter to include it in the name, or maybe they thought it would be plain silly and long to call it Budapestóbuda, who knows… In any case, today you can enjoy the differences in character of the two towns lying on different sides of the blue Danube. Buda, with its green hills, castles, and well-preserved old town, is slow and historical, almost giving a feel of a medieval movie set. It is amazing to think that the city was restored from almost complete destruction during World War II. Across the river lies Pest, with its more modern architecture, lively downtown area, lifestyle, and parties, but still boasting some marvelous sites like the Parliament Building, the Opera House, and St. Stephen’s Basilica, among many others.
Many visitors get excited about Belgrade’s night life and cuisine. Nicknamed “Ibiza of South East Europe”, the city caters to all possible tastes and whims, offering not only extensive indoor, outdoor, and even on-river clubbing, but also the bright and delicious mix of Mediterranean, Germanic, and Turkish dishes in hundreds of local cafes and restaurants. Great wines and the general fantastic quality of produce make the picture almost perfect.
Outside the capital, the country boasts beautiful scenery, including mountains, rivers, and lakes. It does not have beaches, but the neighboring coastal countries like Croatia or Montenegro are just a one-hour flight away. But before you grab your beach shoes, please remember that the Serbian countryside also has a lot of places to go and things to do, especially if you want to experience traditional Serbian life.
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Asset Protection in Serbia
Serbia has signed the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters, which is regarded as a milestone on the path to the implementation of CRS. However, at the moment the CRS framework has not been implemented yet. The Republic of Serbia has not harmonized with regard to automatic exchange of banking information with other countries that have signed the convention or concluded bilateral agreements with them (except FATCA, the agreement with the USA). Information exchanges with other countries are made upon request or spontaneously. In any case, at the moment, Serbia remains, as some lawyers put it, a “CRS-free zone that does not intend to send out external reports on Serbian resident permit holders.
Whatever your status is and whatever country you come from, if you want to know the precise requirements, procedures, and regulations about asset placement and data protection for offshore accounts, you will surely benefit from a consultation with a qualified professional, who can explain the legislation and make suggestions about the best actions for your specific situation.
Serbian Official Residence Permits
Getting a Serbian residence permit is fast, affordable and hassle-free. The chances of refusal a very low, which, among other things, makes Serbia a good “second option” for European residence: the process is so organized and inexpensive that there is really no reason not to go ahead with it.
To apply, you need to start a local company, (which takes 1-2 days and a personal visit to Belgrade), and deposit as little as EUR 1.500 on an account in a local bank. After that, you can leave the country and wait for the decision elsewhere.
Your Serbian residence visa will be ready in a couple of weeks. You are free to enter and leave the country. Initial permits are typically issued for a year, but renewing the residence permit year after year should not be a problem if you meet the minimal compliance requirements, such as filing your company’s account reports.
It is not possible to file an application for the residence permit yourself – you will have to submit it to the Foreigners Department (sort of the local Immigration Office, which technically is a Police department). However, to avoid language obstacles and possible pitfalls, you should seek a consultation with an immigration lawyer, who can advise you on a better way to present your case. Most people find it easier to hire a lawyer who will walk them through the process step-by-step. We can offer you the help of several professional consultants, who are fluent in English and knowledgeable in the Serbian legislation.
If you are not interested in starting a company, you can purchase real estate in order to apply for permanent residence. If this path seems more attractive to you, purchasing real estate will make you immediately eligible, eliminating the need to start a business. There is no minimum investment amount.
In addition, there are other options, like in other countries. For example, you can apply for permanent residence if you marry a local citizen or get a job with a local company.
Please note that a Serbian permanent residence status does not make you a tax resident in the country, but depending on the circumstances you might decide to become one. Serbia has a number of current double tax avoidance treaties with various countries.
Serbian Citizenship by Investment
Officially, the programme of citizenship by investment is not offered by the Serbian Republic. However, surprisingly enough, there is still the opportunity to request it from the Serbian government, which certainly understands its value both for the country and for the foreign investors who are attracted by the idea of the second citizenship. The Serbian government, made a political decision not to be perceived as an agency that “sells” citizenship. There are some legal ways for an experienced law professional to achieve these goals in Serbia, and mind you, we are not talking about using loopholes or participating in “grey” citizenship programmes! However, desirable results may be achieved with proper understanding of the legal intricacies of citizenship laws: for example, a clear discretion is granted to the government in Article 19 of the Serbian Citizenship law:
Irrespective of the conditions from the Article 14 para. 1 points 2 – 4 of this Law, even a foreigner, whose admission to citizenship of the Republic of Serbia would be of interest for the Republic of Serbia, can be admitted to citizenship of the Republic of Serbia. A spouse of a person, who on conditions pursuant to the para. 1 of this Article acquired citizenships of the Republic of Serbia, can be admitted to citizenship of the Republic of Serbia even if the conditions … are not met. The Government of the Republic of Serbia, on a motion of the competent Ministry, decides about admission to citizenship of the Republic of Serbia …
Under this legal provision, Serbia has naturalized a long list of athletes and celebrities, including Brazilian footballer Cléo, actors Ralph Fiennes and Steven Seagal, North American Basketball players DeMarcus Nelson, Charles Jenkins, Kevin Punter, and Danielle Page, and even former Prime Minister of Thailand, Yingluck Shinawatra.
Of course, most of investors prefer to keep a lower profile than sports or cinema stars. However, these examples show that it is indeed possible to get citizenship by investment “informally”.
The country’s banking system is surprisingly well-developed and reflective of the country’s position as the central business hub of the region and its long history as a busy trade crossroads.
Serbia’s economy still strongly depends on cash, and a visitor may be amazed at the hundreds of small currency exchange offices sprinkled about every city and town of the country. The rate of the local currency, the Dinar (RSD), is very close to the Euro, and large purchases, such as real estate or automobiles, are usually made in Euros.
The country is open and welcoming to foreign investments, and one can find both small local banks and big names in the world of banking operating here. The geography of foreign banking operators working in Serbia is very wide. Noteworthy local banks include the huge government-owned Poštanska štedionica Bank (Postal Bank), Bank Intesa Serbia, and Komercijalna Banka Beograd. Among European names, large Austrian banks like Erste Bank, Raiffeisen, well-known major players as Addiko, Credit Agricole, UniCredit, and Intesa have branches in the Republic of Serbia. The Hungarian-based regional bank OTP recently signed a substantial contract with the French Societe Generale. In addition, there are banks from Turkey (such as Halkbank) and the UAE (for example, Mirabank). Worth mentioning is Bank of China, which also runs active operations here. Komercijalna banka and Opportunity Bank are cooperating with the US capital. A German-owned Pro Credit Bank, also present in Latin America, operates on the Serbian market.
It is not a big problem to start a non-resident bank account in Serbia for a foreign (especially European or American) passport holder, though there is a trend towards more rigid regulations. If you are interested in opening such an account in Serbia, now the conditions for it are still fabourable, but you should hurry while the opportunities are there. It is also legal and theoretically possible to open a corporate non-resident account in Serbia. However, if you are not an owner of a non-resident corporate account yet, Serbian banks sadly tend to decline most applications for non-resident corporate accounts due to the international political pressure. Fortunately, there is a unique solution aimed at business owners in this situation, and we will discuss it below.
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Serbian Bank Accounts and Substance for Offshore Companies
Some owners of offshore businesses in the Seychelles, Nevis, Panama or British Virgin Islands encounter problems when trying to open bank accounts and do business in many parts of the world. A lot of banks request additional proof of substance (such as tax ID numbers, audit reports, evidence of transactions or office rental contracts).
Serbia offers a unique and comfortable solution for this problem: you can start an official branch of your offshore company in this country. Setting up the substance can be done remotely within a short time period for a fee of several hundred euros a month. Following is the list of required documents (verification, such as apostilles etc, may be required):
- a Serbian tax number;
- a multi-currency account in an international bank
- publicly filed accounts audited by an authorized accountant (equivalent to CPA or chartered accountant);
- utility bills and/or office lease in its name;
The company owner will need to pay the annual corporation tax on the branch profits, which in Serbia generally amounts to 15%. The interesting feature is that there is an option to book the business through the branch or the parent company, which represents the same legal entity, but has separate accounting. This solves the problem, because your payments are being transferred within the same company, therefore they are not part of the taxable income (capital contributions to fund the branch). The Serbian branch of the company will be regarded as a local entity, and as such will have unimpaired access to all major international banks via the multi-currency Serbian IBAN. This choice involves working with large European banks, so the requirements to documents and procedures are not extensive, and deadlines for processing payments are strictly observed. The company is expected to send invoices to back up its transactions, but generally nothing else is demanded by the banks.
If at some later point the Serbian branch is closed, its assets will still belong to the main offshore company and can be transferred back at any moment, without running a complicated liquidation process.
To add further substance to a business, the company owner can hire local Serbian employees and outsource some of the company’s functions to them (especially, HR, accounting, IT, book-keeping, client support, etc.). It is possible to hire well-qualified specialists with great command of English, and pay fairly moderate salaries in Serbia.
Local Equivalent of “Private Interest Foundation” – Serbian Endowments
Serbia is not the first country most people will look to when they consider opening an offshore company in order to protect their assets. However, the country has some interesting options to offer.
Serbia’s Law on Endowments and Foundations, adopted in 2010, provides for two categories of non-membership for non-profit organizations: Foundations and Endowments.
The Foundation outlined by this law is somewhat similar to the concept of a Public Foundation known in other jurisdictions. However, unlike in Panama, there is no provision in Serbia for a Private Interest Foundation, therefore it is a good choice for those looking for a non-profit entity for philanthropic or charity purposes or public projects.
Serbian endowment is similar to the Private Interest Foundation existing in Panama or a “trust” that has its own legal status. Broadly speaking, the Endowment can be compared to a common-law Trust in Nevis. The minimum capital required in order to establish a Serbian Endowment is the amount equivalent to 30,000 Euros paid in Serbian Dinars. The endowment could hold stocks, bank accounts, and even underlying commercial businesses, located anywhere in the world. Both new Serbian residents and non-residents can set up Serbian Endowments for wealth management, asset protection, and tax planning purposes. Serbian Endowment can also be set up for private purposes; for example, to run a family office, to manage succession planning, and even to run commercial operations.
The assets of the Endowment cannot be distributed among the founders, members of the governing bodies, employees or affiliated persons. However, the Founders’ family members can be named as the beneficial owners. The fact that the founder of the Endowment has no legal control over the funds means that a foreign creditor cannot pressure the founder to access them, which is a beneficial feature for asset protection.
Following the EU and OECD standards, Serbia runs a public register of beneficial owners of all legal entities. The fact that banks can easily verify a company’s beneficial ownership makes it easy to open bank accounts in the country. According to the government-issue guidance Beneficial ownership is defined as follows: “the Manager or Trustee of the endowment should be registered as the Beneficial Owner”. Thus, either the founder or the beneficial owners have to be listed in public documents.
Investing in Serbia
It seems that the strategy of the Serbian government for attracting foreign investment is quite successful. In recent years, Serbia was # 1 most attractive country for foreign investments for four years in a row. Its strong FDI track-record is substantiated by internationally recognized awards. Serbia maintained its global number one spot as country that creates most FDI jobs per million inhabitants, according to “IBM Global Location Trends 2020“. IBM Global Locations Trends 2020 report noted that “Serbia continued to show strong results for the fourth year in a row, as the next wave of preferred locations for companies in Europe.” Serbia outperforms such countries as Hungary, Croatia, Bulgaria, and Greece in the ease of doing business and making investments.
The country also enjoys respectably high rankings from international financial agencies. Fitch gave it a BB+ rating and described the country’s prospects as “stable”. Moody’s rated Serbia at Ba3. There is more up-to-date information on foreign direct investment on the website of the government-run Development Agency of Serbia (https://ras.gov.rs/).
There is currently a boom of investing in Serbian real estate. The prices are quite reasonable, and the procedures are client-friendly. It is worth mentioning that many investors tend to buy the property in Serbia that they actually intend to live in. Many of them in an attempt to maximize the benefits of the Serbian real estate sector, are choosing large luxury apartments in the old city center.
The real estate market in Serbia shows positive dynamics in almost all the important parameters (including vacancy rates, yields, investment volumes, number of new investors, etc.). There is also room for further development, especially if we compare it to the neighbouring EU countries in Croatia, Romania or Bulgaria. Therefore, there is great potential for capital gains and making profit on rental returns.
Corporate funding (especially from the USA, Middle East, Israel, and Africa) is also being actively invested into Serbian real estate. One of the most well-known examples of such mutually beneficial cooperation is the Belgrade Waterfront project started in 2014 with an investment of 4 billion Euros from Abu Dhabi.
There is also good potential in the investments into agricultural land. Traditionally, Serbia is an agricultural country, and even today over 1 million out of the total 7 million people living here are employed in agriculture. The sector has received support from the EU in the form of the EUR 175 million Investment for Pre-Accession Assistance for Rural Development (IPARD) between 2014-2020. Lately there has been a slight decline in the agricultural production in the country, but it certainly offers plenty of opportunities to make profit there. Recently, Serbia has tightened up the legal requirements for foreign land ownership as part of its efforts to eventually become an EU member state. However, in practice, these restrictions can easily and safely be evaded by setting up a local company.
On the fertile land in the north of Serbia (the region of Vojvodina) there is a well-developed and diversified production of high value crops, namely fruits and nuts. The lands in the south are less productive. However, most of the country’s area can offer perfect conditions for producing high-value crops, such as walnuts, hazelnuts or blueberries. Or maybe you as an investor would prefer to own a winery or a vineyard? Or both? Wine production in Serbia is a profitable lifestyle investment with good prospects.
Serbia is a hospitable and investor-friendly European country rich in human and natural resources and welcoming to international business. It can offer a foreigner a multitude of benefits both for a comfortable carefree life and for successful business in close connection with the EU space. If you are interested in enjoying the opportunities offered by this country, choosing the optimal and most profitable ways to work here, and avoiding the most treacherous pitfalls, you should seek expert help and advice from experienced legal and financial professionals. In this case, your business, investment and personal experience in Serbia can become a real delight.