The Law on Amendments to the Law on Value Added Tax (“Official Gazette of the RS”, No. 94/2024, the “Law”) came into force on December 15, 2024. For the most part the Law will start to apply as of January 1, 2025. There are, however, two exceptions, one of them being the Preliminary Tax Return filings.

 Preliminary Tax Return

Introduction of the preliminary value added tax return is one of the most significant changes to the Law. Provisions regarding the preliminary tax return will start to apply from the January 2026 tax period, i.e. the January-March 2026 period.

The preliminary tax return represents a set of data related to the supply of goods, the supply of services, the import of goods, and other transactions and activities that affect the tax liability of a VAT taxpayer and is prepared in the Electronic Invoicing System (“SEF”).

The VAT taxpayer shall file a tax return together with the preliminary tax return, as an attachment to the tax return. If the VAT taxpayer fails to file the tax return within the prescribed deadline, the preliminary tax return needs to be filed with the tax authority at its request.

The form, content, and method of preparing and filing the preliminary tax return will be regulated in more details by the competent ministry.

Changes to the VAT Base

The Law regulates in more detail the conditions and procedures in cases of increase or decrease in the tax base, particularly in relation to the VAT taxpayer who has carried out the supply of goods and services, as well as depending on whether the recipient of the goods and services is in the VAT system or not, i.e., whether they have the right to input tax deduction.

Input Tax Deduction

The general conditions for the right to deduct input tax have remained unchanged.

The method for determining the tax period for which a VAT taxpayer can exercise this right has been regulated. Specifically, a VAT taxpayer can exercise the right to deduct input tax for a tax period based on an electronic invoice if the electronic invoice is accepted no later than the 10th day of the calendar month following the tax period. If the electronic invoice is accepted starting from the 11th day of the calendar month following the tax period for which the tax return is filed, the VAT taxpayer can exercise the right to deduct input tax for the tax period in which the electronic invoice was accepted.

A VAT taxpayer who has not exercised the right to deduct input tax based on an invoice issued by another VAT taxpayer for an advance payment can exercise the right to deduct input tax based on an invoice for the supply of goods or services, by creating an internal invoice.

VAT Taxpayer Registration Deadline

The deadline for registering a VAT taxpayer has been changed. Now, a taxpayer who has achieved a total turnover greater than eight million dinars in the previous 12 months is required to file a registration statement with the tax authority within five days from the date the turnover was achieved.

Change of the Tax Period

Starting from December 20 through December 31 of the current year, for the following calendar year, a taxpayer, who has achieved a total turnover of less than 50,000,000 dinars in the previous 12 months (except for taxpayers who pay tax obligations under the cash accounting system), can file a request with the tax authority to change its tax period to a calendar month. In this part, the Law became applicable as of December 20, 2024.

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