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      Parliament of Serbia adopted the Law on Amendments to the Law on Tax Procedure and Tax Administration (hereinafter: the Law on Amendments to the LTPTA), which was published in the Official Gazette of the Republic of Serbia no. 109/2025 of 4 December 2025.

      The Law on Amendments to the LTPTA enters into force on 12 December 2025.

      The most significant novelties are presented below.

      Elimination of Irregularities in the Use of Tax Incentives

      If, during a tax audit, it is determined that the employer does not meet the conditions for tax incentives:

      • The Tax Authority issues a decision ordering the employer to pay the tax and contributions that were previously paid from the state budget.
      • The employer is not required to submit amended tax returns to correct the irregularities.

      Extension of deadline for implementation of debt and overpayment write-offs ex officio

      The deadline for completing of writing off debts and overpayments on various grounds of termination, which, according to the proposed amendments, the Tax Authority should carry out ex officio, is extended until 31 December 2026.

      The deadline for completing the procedure, which aims to organize the accounting and other records of the Tax Authority, is extended until the end of 2026 in order to provide additional technical and IT capabilities for the efficient implementation of debt and overpayment write-offs in the coming period.

      Additionally, since the efficiency of organizing the Tax Authority’s records depends on the quality of relevant information received from the records of original authorities, the additional deadline is intended to ensure more effective cooperation between state authorities, as well as to find ways to provide reliable, accurate, and indisputable data.

      Implementation of Write-Offs ex officio Without a Decision

      In order to streamline the procedure, the write-off in tax accounting of debt and overpayment of amounts up to RSD 100 will be carried out based on a record prepared by the Tax Administration.

      Payment of Taxes in Foreign Currency – Deferred Implementation

      The implementation of the provision regarding the payment of taxes in foreign currency by non-residents is postponed for one year, so that the starting date for its application is set for 1 January 2027.

      Igor Lončarević

      Partner, Head of Tax & Legal

      KPMG in Serbia and in Montenegro

      Biljana Bujić

      Partner, Tax & Legal

      KPMG in Serbia and in Montenegro


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      Amendments to the Law on Tax Procedure and Tax Administration 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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