Amendments to the Value Added Tax Rulebook adopted

The Serbian Ministry of Finance adopted the Amendments to the Rulebook on Value Added Tax (Rulebook), which were published in the Official Gazette of the Republic of Serbia No. 30/2026 dated 27 March 2026.

The changes apply from the April tax period, i.e. April – June 2026.

The provision relating to changes of the tax base have been specified

- Determining the VAT base by estimation

The Rulebook elaborates on the rules applicable in situations where, on the day the tax liability arises, the exact amount of the tax base is not known.

Specifically, the provisions have been clarified so that the rules on determining the base by estimation apply in cases where the recipient of goods or services is the tax debtor.

Additionally, it is now provided that a VAT payer who performs supply and is the tax debtor for that supply determines the base by estimation only when the base depends on data provided by third parties.

In both cases, the rule applies that when the actual amount of consideration becomes known, the difference is treated as a change of the tax base within the meaning of Article 21 of the VAT Law and is reported in the tax period in which the base became known.

- Subsequent changes of the VAT base and calculated VAT

The Rulebook clarifies that any change to the tax base, whether an increase or a decrease, is made for the tax period in which the change occurred.

The conditions for reducing the calculated VAT on the basis of a reduction of the tax base have been further specified in order to align with the amendments to the VAT Law.

Additionally, in the case of a subsequent discount on the price for a performed supply of goods or services, the Rulebook emphasizes that the reduction of the tax base is deemed to have been made at the moment when the conditions for granting the discount or other reduction of consideration, in accordance with the contract, have been fulfilled, regardless of when the document on the reduction will be issued.

Furthermore, the obligation to issue a document on the reduction has been prescribed in the case of a subsequent reduction of the tax base for VAT calculation for a supply for which the VAT payer making the supply is the tax debtor.

The Rulebook is aligned with the VAT Law so that the reduction of the calculated VAT is made for the tax period for which, by the day preceding the day of filing the tax return for that period, and at the latest by the 10^th day of the calendar month following that tax period, the conditions for the reduction have been fulfilled.

- Return of goods

One of the most significant amendments introduced by the Rulebook is that, in all cases of return of goods, the rules on reduction of the tax base apply, and not only in certain cases of return of goods as previously prescribed.

- Last day of the period as the date of decrease/increase

The Rulebook prescribes that, in the case of an increase of the tax base in accordance with a contract, as well as in the case of a decrease of the tax base, the VAT payer is not required to determine the exact date on which the increase or decrease occurred. It is sufficient to determine the tax period in which the change of the tax base was made, and the last day of that tax period may be indicated as the date of the increase/decrease.

- One document for increases/decreases

Under the amendments to the Rulebook, if, within a single tax period and on the basis of a concluded contract, there is a change in the consideration, i.e. the tax base, for supplies already made on several grounds, the VAT payer may issue one consolidated document of increase for all increases, or one consolidated document of decrease for all decreases. The last day of that tax period is to be indicated in the document as the date of the increase/decrease.

Adjustments of input VAT and cancellations – a new level of detail

- Decrease of input VAT

The Rulebook further strengthens the role of corrective documents, so that the obligation of the recipient of goods and services to adjust/reduce input VAT, under the new rules applicable as of the April tax period, arises only upon the issuance of a document of decrease by the supplier, and not merely on the basis of the fact that the tax base has been reduced. In connection with this, an explicit obligation has been introduced to issue a document of decrease in the event of a reduction of the tax base.

The Rulebook lays down in detail the deadlines within which adjustments of input VAT are to be made. Under the new rules, a VAT payer makes an adjustment/reduction of the input VAT deduction for the tax period for which, at the latest on the day preceding the day of filing the tax return for that period, and no later than the 10^th day of the calendar month following that tax period, it holds the document for the decrease.

Additionally, a recipient of goods who has accounted for VAT as the tax debtor (reverse charge) and has used such VAT as input tax is required, in the event of a subsequent reduction of the tax base for that supply, to adjust/reduce the input VAT deduction regardless of whether the entity making the supply has issued a reduction document or another document. This reduction is made for the tax period in which the tax base was reduced.

- Increase of input VAT

The rules on the increase of input VAT due to an increase of the tax base and the calculated VAT are now regulated in more detail and with greater clarity. Under the Rulebook, where a VAT payer is entitled to deduct input VAT on the acquisition of certain goods or services, it is also entitled to deduct the VAT calculated on the subsequent increase of the tax base for VAT purposes for that supply, i.e. to increase the input VAT on that basis. This right is exercised on the basis of a document of increase issued in accordance with the VAT Law.

A VAT payer exercises the right to deduct/increase the input VAT due to an increase of the tax base at the latest for the tax period in which the tax base was increased, provided that, by the day preceding the day of filing the tax return for that period, and no later than the 10^th day of the calendar month following that tax period, it holds the document for the increase.

Furthermore, a recipient of goods and services who has calculated VAT as the tax debtor on the supply made to it is entitled to increase the input VAT on the basis of an increase of the tax base for VAT purposes, if the requirements for exercising this right are fulfilled for the relevant tax period – namely, if it has issued a self‑invoice and has calculated VAT in accordance with the law, and if the goods and services are used for supplies of goods and services giving rise to the right to deduct input VAT. The right to deduct input VAT on the basis of a self‑invoice may be exercised for the tax period for which the self‑invoice was issued, and no later than on the day preceding the day of filing the tax return for that tax period, and in any event no later than the 10^th day of the calendar month following that tax period.

- Adjustment of input VAT due to cancellation of invoices and other documents

Under the Rulebook, the manner of adjusting input VAT on the basis of the cancellation of a received invoice or another document affecting the right to deduct input VAT depends on whether the cancelled document was issued in accordance with the VAT Law and the Rulebook (i.e. whether it is formally correct) or not.

If the invoice (or another document) was issued in accordance with the VAT Law and the Rulebook – and the tax payer was entitled to deduct input VAT based on that document – the rules on reduction or increase of input VAT apply.

If the invoice (or other document) was not issued in accordance with the VAT Law and the Rulebook, a VAT payer who has exercised the right to deduct input VAT on that basis is obliged to submit an amended tax return in accordance with the Law on Tax Procedure and Tax Administration.

Depending on the type of cancelled document, this may result in either a decrease or an increase of the input VAT deduction.

Recipient’s notice on input VAT

The Rulebook provides more detailed regulation of the form, content and manner of delivery of the recipient’s notice on input VAT.

The recipient’s notice on input VAT may be prepared in electronic or other form, and it may also be prepared within the SEF.

The recipient’s notice on input VAT is delivered electronically via SEF or in another appropriate manner.

For the first time, the Rulebook prescribes the mandatory content of the recipient's notice on input VAT. If a VAT payer receives a recipient's notice on input VAT that does not contain all the prescribed elements, its right to reduce VAT on the basis of a reduction of the tax base or an advance payment may be challenged.

Advance invoices

In line with the Rulebook, as of 1 April 2026, where a VAT payer receives an advance payment (in full or in part) on the same day on which it supplies goods, it may issue only a final invoice, but it may also issue an advance invoice even though it is not obliged to do so.

In addition, the Rulebook introduces an obligation to issue an advance invoice where an advance payment is received for a supply for which the VAT payer is not tax debtor under the VAT Law.

An advance invoice may be issued no earlier than on the date of receipt of the advance payment.

Self‑invoice (Internal account)

As of the April tax period (i.e. April–June) 2026, all SEF users will be required to prepare self‑invoices exclusively within SEF, with the document “Individual VAT Record – Internal account” being deemed a self‑invoice. A self‑invoice is considered to have been issued on the date on which the “Individual VAT Record – Internal account” obtains the status recorded in SEF.

The deadline for issuing a self‑invoice has been extended to the 12^th day of the month following the tax period.

However, if a VAT payer wishes to exercise the right to deduct input VAT for the same tax period in which the VAT liability arose, it must issue the self‑invoice no later than on the day preceding the day of filing the VAT return for that period, and in any event no later than the 10^th day of the calendar month following that tax period, regardless of the fact that the general deadline for issuing a self‑invoice is the 12th day of that month.