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HMRC internal manual

Double Taxation Relief Manual

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Yugoslavia: History

Until 1991 Yugoslavia was a Socialist Federal Republic comprising the Republics of Serbia, Croatia, Macedonia, Montenegro, Slovenia and Bosnia-Herzegovina, as well as the autonomous Serbian provinces of Kosovo and Vojvodina.

In mid-1991, Slovenia and Croatia disassociated themselves from the Federation.

In April 1992, the Federal Republic of Yugoslavia, comprising Serbia and Montenegro, was established but in June 2006 Serbia and Montenegro became independent states and the state union of Serbia and Montenegro ceased to exist. In respect of Serbia and Montenegro the 1982 Double Taxation Convention (see DT20651) between the United Kingdom and Yugoslavia is regarded as having remained in force.

Following the recognition of Croatia and Slovenia by the United Kingdom, both those States, and also Macedonia, independently committed themselves to continue to honour all obligations under Yugoslavia’s international agreements, including the Double Taxation Convention between the United Kingdom and Yugoslavia (see DT20651 onwards for details of the agreement and also the separate entries under Croatia, Macedonia and Slovenia).

The United Kingdom has agreed to a bilateral Double Taxation Agreement with Macedonia. The agreement entered into force on 8 August 2007, effective in the United Kingdom from 1 April 2008 for corporation tax and 6 April 2008 for income tax and capital gains tax.

The United Kingdom has signed a Double Taxation Agreement with Slovenia. It entered into force on 11 September 2008, effective in the United Kingdom from 1 April 2009 for corporation tax and 6 April 2009 for income tax and capital gains tax.

Kosovo does not accept that the UK/Yugoslavia Convention applies.

The application of the UK/Yugoslavia Convention to other parts of what was Yugoslavia is unclear. Claims for relief in respect of tax imposed in Bosnia-Herzegovina should be referred to Business International, Tax Treaty Team.