The Serbian Ministry of Finance initiated on 10 October the public consultation on amendments and supplements of the several important laws (i) Law on Value Added Tax, (ii) Law on Electronic Invoicing, (iii) Personal Income Tax Law, (iv) Law on Mandatory Social Security Insurance, (v) Law on Electronic Delivery Notes and (vi) Law on the Republic Administrative Fees (“the Laws”).
The public consultation will last until 17 October. Any interested party may propose amendments to laws.
Below is a short overview of the main amendments to the provisions of these Laws:
Proposed amendments and supplements to the Law on Value Added Tax (hereinafter: “VAT law”)
What are some of the amendments and supplements to the VAT law?
- added definition of the tax debtor, which now includes the person who issues an internal invoice and the recipient of investment gold,
- new rule for the time of supply of the goods for which the periodic invoices are issued.
- new rules on subsequent decrease of the VAT base,
- clarification on deduction of input VAT under fiscal receipts and internal invoices,
- additional regarding the correction of the input VAT deduction in case of a correction in the tax base for the taxable supply of goods and services, as well as advance payment and cancelled invoices,
- application of provisions regarding the preliminary VAT return is extended and will start to apply from 2027.
Proposed amendments are set to take effect for the tax period April 2026 (April-June 2026). Relevant bylaws will be adopted within 60 days of the date the proposed amendments come into force.
Proposed Amendments and supplements to the Law on Electronic Invoicing (hereinafter: “E-invoicing Law”)
What are some of the key changes?
- Storage of the documents which are processed and created in the electronic invoice system (“SEF”) is now prescribed.
- The e-invoicing obligation exists for:
- retail trades to the corporate cardholder.
- retail trades to the public sector entity.
Electronic recording of VAT calculations does not apply to a taxpayer who hasn’t issued an invoice.
A legal provision is being introduced to enable the reception of electronic invoices issued in compliance with the European e-invoicing standard. However, this will only be possible once the necessary technical conditions are met within the SEF.
Bylaws will further clarify the procedure for the storage of the documents in SEF.
The amendments to the proposed amendments and supplements to the E-invoicing Law are expected to take effect for tax periods beginning after 31 March 2026. Relevant bylaws will be adopted within 60 days of the date the proposed amendments come into force. With a remark that the provisions concerning the preliminary VAT return are set to be extended and applicable as of 31 December 2026.
Proposed Amendments and supplements to the Personal Income Tax Law
What are some of the key changes?
Non-taxable amount for salary will be RSD 34.221 in 2026.
Application of the tax incentives from Articles 21v (employment of new individuals) and Article 21d (employment of new individuals with micro and small legal entities and entrepreneurs) has been extended until 31 December 2026. Amendments do not prescribe extension of tax incentive for qualified employees, which was applicable from 2020.
Additional rules on filing of tax returns for different types of income are prescribed to set the obligation or right to file the electronic tax returns.
The proposed amendments and supplements are set to apply as of 1 January 2026.
Proposed Amendments and supplements to the Law on Mandatory Social Security Insurance
What are some of the key changes?
Application of the SSC incentives from Article 45 (employment of new individuals) and 45v (employment of new individuals with micro and small legal entities and entrepreneurs) is prolonged until 31 December 2026.
The proposed amendments and supplements are set to apply as of 1 January 2026.
Proposed Amendments and supplements to the Law on Electronic Delivery Notes
What are some of the key changes?
Significant amendments include:
New rules which exclude the obligation of issuing an electronic delivery note in case of:
- supply of aircraft with fuel and lubricant as long as the place of dispatch and place of receipt are the same airport,
- the movement of goods in which the goods or part of the goods are returned by the same means of transport immediately after delivery.
Number of paper delivery notes in case of a malfunction or deficiency in the system, and the record of the sent electronic receipt, as well as the sanction for not recording the missing data once the deficiencies and malfunctions have been removed.
The proposed amendments and supplements to the law, as well as the law itself, are set to take effect on 1 January 2026.
Proposed Amendments and supplements to the Law on the Republic Administrative Fees
What is the most significant amendment?
A new concept of electronic payment of the administrative fees is officially introduced in the proposed amendments. Moreover, the proof of the payment of the administrative fee will be the data of the payment, which is contained in the electronic system.
Further amendments include the adjustment and increase of tariff amounts to ensure alignment with current standards.
The information in this document does not constitute legal advice on any particular matter and is provided for general informational purposes only.
