Adopted Amendments to Tax Legislation

We would like to remind you that, on 31 August 2026, the National Assembly of the Republic of Serbia adopted amendments to several tax laws. Below is an overview of the most significant changes.

1. Law on Tax Procedure and Tax Administration

The Law on Amendments to the Law on Tax Procedure and Tax Administration entered into force on 8 September 2026, except for Article 7, which governs the automatic settlement of excise duty liabilities and applies as of 1 February 2027. The most significant amendments include:

Unlimited number of amended tax returns – Taxpayers are now permitted to submit amended tax returns, including returns filed ex officio, an unlimited number of times within the statute of limitations. This rule also applies to returns submitted before the Law entered into force.

Expanded scope of ex officio tax return filing – The Tax Administration will file tax returns on behalf of taxpayers who fail to submit their annual personal income tax or VAT returns within the prescribed deadline, as well as in cases identified during a tax audit. VAT returns filed ex officio will be based on the calculated VAT reported in the preliminary VAT return available in the Electronic Invoicing System (SEF), without taking input VAT into account.

Changes to interest and statute of limitations rules – The rules governing the extension of tax return filing deadlines and the calculation of interest on tax liabilities assessed during a tax audit have been clarified. In addition, the suspension of the statute of limitations has been extended to taxpayers’ rights to tax refunds, tax credits, VAT reimbursements, VAT refunds and the reallocation of tax overpayments.

2. Corporate Income Tax Law

The amendments to the CIT Law provide for the gradual abolition of certain tax incentives.

As of 1 January 2027, the following incentives will be abolished:

• The tax credit for investments in the capital of newly established companies engaged in innovative activities, as provided for under Article 50j of the Law.
• Tax exemptions relating to certain transfers of assets and real estate to a concession grantor in connection with the implementation of concession agreements.

The transitional provisions allow these incentives to continue to be used when determining corporate income tax for 2026.

As of 1 January 2028, the following incentive will be abolished:

• The ten-year corporate income tax exemption for investments in fixed assets and employment, provided for under Article 50a. Transitional rules allow taxpayers who meet the prescribed conditions by the end of 2027 to retain their entitlement to this incentive.

As of 1 January 2027, withholding tax at a rate of 1% will be abolished on fees paid by resident legal entities for the purchase of secondary raw materials and waste from resident and non-resident legal entities.

The amendments to the CIT Law also introduce further alignment of domestic tax legislation with European Union legislation. The application of certain provisions, including those relating to cross-border corporate reorganisations, the tax treatment of dividends, interest and royalties, and the prevention of tax avoidance, has been postponed until the date of Serbia’s accession to the European Union.

3. Value Added Tax Law and Amendments to the Related Rulebooks

Amendments to the VAT Law

• Mandatory period of VAT registration – The minimum period for which small taxpayers, farmers who have voluntarily registered for VAT, and taxpayers who entered the VAT system after exceeding the RSD 8 million threshold must remain VAT-registered is reduced from two years to the current and following calendar year.
• Ex officio filing of VAT returns – The Tax Administration will be entitled to file a VAT return on behalf of a taxpayer who fails to submit one within the prescribed deadline. The return will be based on the preliminary VAT return generated in SEF and will include only information on calculated VAT, excluding input VAT.
• Shorter deadline for deregistration from the VAT register – The deadline for submitting a request for deregistration from the VAT register, or for a legal successor to submit a notification in the event of a corporate status change, is reduced from 15 to 5 days from the relevant event.
• Deadline for filing a VAT return upon deregistration – A taxpayer being deregistered from the VAT register, or the legal successor of a taxpayer ceasing to exist as a result of a corporate status change, must submit a VAT return within 15 days of ceasing its VAT activities, rather than on the date the deregistration request is submitted.
• Changes to forms and transitional rules – A specific transitional rule applies to late-filed and amended VAT returns relating to tax periods ending with October–December 2026, or December 2026, as applicable. Under this rule, the VAT calculation breakdown is not required to be submitted together with the tax return.

Amendments to the VAT Rulebook

• Preliminary VAT return – A new PPP PDV form is introduced. At the taxpayer’s request, the form will be generated in SEF based on the available data and submitted to the Tax Administration as part of the VAT return. The rules governing preliminary VAT returns apply to tax periods beginning after 31 December 2026.
• VAT records and input VAT – The relevant forms and supporting schedules are amended, and the rules for recording supplies, purchases, input VAT and input VAT adjustments are clarified. The deadlines and procedures for the electronic recording of input VAT in SEF are also further regulated, including the correction and updating of recorded data.
• VAT adjustments and refunds – The rules governing the cancellation of invoices and adjustments to calculated VAT and input VAT are clarified, together with the forms used for VAT refunds and reimbursements.

4. Law on Electronic Invoicing

• Electronic recording of purchases from farmers – The scope of electronic VAT recording is expanded to include purchases of agricultural and forestry products and agricultural services from farmers who are not registered for VAT. The obligation to record such transactions rests with the VAT taxpayer receiving the supply in the Republic of Serbia. Transactions are recorded in aggregate for the relevant tax period, after its end and no later than the 12th day of the following calendar month. This amendment applies as of 1 July 2027.
• Cross-border transactions – exports and dispatches of goods – The definition of cross-border transactions is expanded to include information on the export or dispatch of goods. The relevant information will be displayed in SEF based on data obtained from the Customs Administration’s information system.

The Law entered into force on 8 September 2026 and generally applies as of 1 January 2027, except for the provisions concerning the electronic recording of purchases from farmers and customs declaration lists for the export or dispatch of goods, which apply as of 1 July 2027.

5. Personal Income Tax Law and Law on Mandatory Social Security Contributions

Extension of the Period for Applying Tax Incentives

The period during which incentives for employing new employees under Articles 21v and 21d of the Personal Income Tax Law may be used has been extended until 31 December 2028. This provides employers with additional time to plan recruitment and employment costs.

Changes to the Eligibility Conditions for Tax Incentives

• The requirement for an individual to have been registered with the National Employment Service for at least six months will not apply to certain categories of young people registered under the “Youth Guarantee” programme. For employment commencing by 31 December 2027, this exception applies to individuals up to 30 years of age. For employment commencing as of 1 January 2028, it applies to individuals up to 24 years of age, subject to the statutory conditions.
• As of 1 January 2028, tax incentives may be used for a maximum of 12 months from the date of hiring a new employee, provided that employment increases the employer’s net headcount compared with the average number of employees during the preceding 12 months.
• Additional restrictions will apply from the same date: the total amount of tax and social security contribution incentives may not exceed 50% of the wage costs of newly employed individuals or EUR 5.5 million per employer per year.
• Employers required to repay state aid or de minimis aid, as well as employers considered to be undertakings in difficulty, will not be entitled to these incentives.

Incentive for Employing Persons with Disabilities

The rules governing incentives for employing newly hired persons with disabilities have also been amended to further align their application with state aid control regulations.

Should you require any additional information or clarification, the TPA team remains at your disposal.