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      At its session held on 3 December 2025, the National Assembly of the Republic of Serbia adopted the Law on Amendments to the Law on Electronic Invoicing (Law). The Law was published in the Official Gazette of the Republic of Serbia No. 109/2025 as of 4 December 2025.

      The Law entered into force on 12 December 2025 and shall apply for tax periods starting after 31 March 2026, with the exception of the provision related to the preparation of the preliminary tax return, which applies as of the date when the Law enters into force.

      Retail supply to corporate card holder and public sector entity

      Amendments to the Law introduce the obligation to issue an electronic invoice for retail supply:

      1. Performed to a corporate card holder, as well as in the case of an advance payment received for such retail supply;
      2. Provided to a public sector entity, if the public sector entity has submitted a request for issuance of electronic invoice, within seven days as of the day on which retail supply is performed.

      In these cases, the electronic invoice is not to be issued before a fiscal receipt has been issued, in accordance with fiscalization legislation.

      System of Electronic Invoicing

      It is envisaged that the System of Electronic Invoicing may be used for creation, sending, receiving, storage, and processing of other documents in relation to transactions, e.g. statement from the buyer on the correction of input VAT, which was enabled on SEF in the previous period.

      Preliminary tax return

      Application of the provision related to the preparation of the preliminary VAT return has been delayed, and in accordance with the respective amendments, shall apply to tax periods starting after 31 December 2026.

      Igor Lončarević

      Partner, Head of Tax & Legal

      KPMG in Serbia and in Montenegro

      Biljana Bujić

      Partner, Tax & Legal

      KPMG in Serbia and in Montenegro


      Amendments to the Law on Electronic Invoicing adopted

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      The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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