On the 28th November 2024, amendments on the law on e-invoicing was published on the official gazette.

Timeline

Amendments will be effective on different dates:

• Most of the amendments will apply from January 1, 2025.
• Articles 3 (declaration of VAT status) and 12 (the role of Central Intermediary System(CIP)) will be applicable from December 15, 2024.
• Articles 4 (VAT Reporting Requirements) and 5 (System User requirements) will apply to VAT tax periods starting after December 31, 2024.
• Article 7 (e-invoice content) will apply to VAT tax periods starting after December 31, 2025.

Impact

Amendments are related to the following topics:

• Obligation to declare the VAT status within 5 days of registration or change in the status. VAT status refers to:
  • Whether the subject is a VAT taxpayer;
  • Whether the VAT tax period for the subject that is a VAT taxpayer is a calendar month or a calendar quarter.
• Recording VAT on imports and earlier-stage VAT must be done electronically for each tax period
• VAT status has become a mandatory content for e-invoices
• Users of the system can now view data on imports and the customs status of goods through access to the Customs Declaration List.
• A list of users (public) will be maintained, containing the tax ID of system users, and users can be removed from the list if certain conditions are met
• The status of subjects in the CIP system can now be automatically updated based on data from the Tax Administration
• The liability of information intermediaries (service providers) has been explicitly defined, with the ability for authorities to revoke licenses for non-compliance
• Private sector invoices must be stored for 10 years after the end of the calendar year in which the invoice was issued
• Penalties have been introduced for non-compliance with various obligations, including:
  • Failure to issue an electronic invoice: Fines range from 200,000 to 2,000,000 RSD.
  • Failure to declare VAT status or update status data: Subject to fines of up to 2,000,000 RSD.
  • Failure to maintain electronic VAT records: Penalties up to 2,000,000 RSD.
  • Use of system data for unauthorized purposes: Also subject to fines.
  • Liability extends to legal entities, responsible persons, and entrepreneurs

Taxpayers subject to Serbian e-invoicing must assess these changes and implement necessary measures to stay compliant.