Regulatory updates - Serbia

The Serbian Parliament adopted amendments to the VAT law. One of the key changes is the introduction of pre-filled VAT returns starting from January 2026. 

Pre-filled VAT returns  

A pre-filled VAT return is data on the turnover of goods, trade in services, import of goods and other transactions and activities that determine the VAT payer’s tax liability. 

Starting from the January 2026 VAT period:  

• The Tax Authority will generate pre-filled VAT returns in the electronic invoicing system (SEF) using information available in the system.  

• Pre-filled VAT returns will not be generated for periods in which VAT activity begins or ends. 

• Taxpayers will be required to submit their VAT returns together with a pre-filled tax return as an annex to the tax return.  

• If the taxpayer fails to submit the return within the deadline, the Tax Authority may use the pre-filled VAT return as final.  

The requirement to file the VAT calculation overview for each tax period will be eliminated starting with the January 2026 tax period.  

According to the amendment to Article 22 of the Rulebook, the Serbian Ministry of Finance will not impose fines for VAT reporting discrepancies in the SEF system until December 31, 2025, though penalties may be reinforced after this date. During this period, the Ministry of Finance will disregard errors in VAT record data while evaluating the correctness of the electronic VAT recording.

The extension of the grace period follows provisions that were previously established under the Rulebook on Electronic Invoicing which was published in the Official Gazette No. 107/24 on December 30, 2024, and entered into force on January 1, 2025, with some exceptions. The Rulebook specified that between January 1, 2025 and June 30, 2025, the Ministry of Finance would not penalize errors in electronic VAT records submitted to the SEF system.

Additionally, effective July 1, 2025, the same rulebook introduced new requirements for credit and debit notes. According to Article 14 p. 1(3), taxpayers must now include in these documents the date when the increase or decrease occurred and the date when the credit or debit note was issued.

The final version of the law largely mirrors the provisions outlined in the draft published in September 2024. Under the current law, both private and public entities are obliged to issue electronic delivery notes for each movement of goods, before transportation. Subsequently, carriers are required to present these electronic delivery notes during inspection processes. The implementation timeline is as follows:

From 1 January 2026:

1. General movement of goods:
   • Public entities must send and receive e-delivery notes in G2G, G2B, and B2G transactions
   • Private entities must send e-delivery notes in B2G transactions
   • Carriers must present the e-delivery notes during the inspections.
2. Movement of excise goods:
   • Private entities must send and receive e-delivery notes in B2B and G2B transactions
   • Carriers must present the e-delivery notes during the inspection.

From 1 October 2027:

1. General movement of goods:
   • Private entities must send and receive e-delivery notes in B2B and G2B transactions
   • Carriers must present the e-delivery notes during the inspection.

The by-laws that will further regulate the process of sending, receiving, and presenting electronic delivery notes will be adopted within 90 days from the date the law entered into force.