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5.5. Source Rules with Respect to Income Derived by Non-Residents

Following payments / income categories are deemed to be sourced in FBiH:

  • Dividends (share of profits) and interest received by non-resident
  • Royalties and other Intellectual property 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
  • Compensation for telecommunication services
  • Other payments for service performed in the territory of FBiH

Following payments / income categories are deemed to be sourced in RS:

  • Dividends and shares in profit
  • Interest, royalties and other payments for Intellectual Property rights
  • Payment for performance of entertainment, art, or sports program conducted in RS
  • Payments for market research, advertising and promotion, management, consulting, tax and business consulting, and services of auditors, accountants, and lawyers
  • Insurance and reinsurance premiums
  • Telecommunication services between RS and another country
  • Payments for lease of movable property

Following payments / income categories are deemed to be sourced in BD whether received in BD or abroad:

  • Interest or its functional equivalent under financial instruments and arrangements from a resident
  • Payment for entertainment or sporting activities carried out in BD, regardless of whether the revenue is received by the entertainer or sportsman or by another person.
  • 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 BD or if such payment is deducted for the purpose of determining the tax base
  • Insurance premiums for the insuring or reinsuring of risks
  • Telecommunication services between BD and a foreign state
  • Royalties, payment of lease for movable property
  • Payment for any other services in BD