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Serbia’s Cryptocurrency Regulations: A Complex Landscape

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Belgrade, Serbia - In a developing landscape, Serbia is grappling with the regulation of cryptocurrencies. While the country has not explicitly qualified cryptocurrencies as securities or financial instruments, there are rules that apply to their sale and use.

The Regulatory Framework

According to experts, in cases where cryptocurrencies can be considered financial instruments, the provisions of the Capital Market Agency (CMA) must be applied. However, since cryptocurrencies have not been explicitly qualified as securities, the general civil law rules - particularly the Serbian Obligation Act - would apply instead.

Taxation of Cryptocurrencies

The taxation of cryptocurrencies is also unclear. Serbia has not enacted any specific tax regulations concerning cryptocurrencies, and the Individual Income Tax Act does not specify them as a revenue source subject to income tax. However, experts suggest that income arising from the sale of cryptocurrencies could be considered subject to personal income tax (20%).

Money Transmission Laws and Anti-Money Laundering Requirements

In terms of money transmission laws and anti-money laundering requirements, while crypto-assets are not explicitly regulated in Serbia, provisions of the Law on Prevention of Money Laundering and Terrorism Financing already cover them to a significant extent. The law recognizes the term “virtual currencies” and sanctions money laundering.

The Serbian Criminal Code also criminalizes money laundering, defining it as the conversion or transfer of assets with intent to conceal or misrepresent their unlawful origin. Experts believe that this provision can be interpreted to include crypto-assets, making them subject to anti-money laundering regulations.

Expert Opinion

As the landscape continues to evolve, experts urge caution and emphasize the need for clear guidelines on the regulation of cryptocurrencies in Serbia.

Source: Global Legal Insights - Blockchain & Cryptocurrency Regulation 2021, 3rd Edition