Amendments to the Law on Tax Procedure and Tax Administration Adopted

The Parliament of Serbia has adopted the Law on Amendments to the Law on Tax Procedure and Tax Administration (“Amendments to the LTPPA”), published in the Official Gazette of the Republic of Serbia No. 80/2026 of 31 August 2026.

The Amendments to the LTPPA enter into force on 8 September 2026, except for Article 7 (automatic settlement of excise duties), which applies as of 1 February 2027.

Below are the most important changes.

Unlimited number of amended returns

The previous limitation on the number of amended tax returns is abolished.

The taxpayer may amend:

• The original tax return they filed; and
• The ex officio tax return filed by the Tax Administration, an unlimited number of times, within the statute of limitations period.

This rule also applies to tax returns filed before the Amendments to the LTPPA enter into force.

Extended cases of ex officio tax returns

The Tax Administration will now file tax returns ex officio when the taxpayer fails to file within the statutory deadline:

• The annual personal income tax return; and
• The VAT return.

The ex officio VAT return is prepared based on data from the preliminary VAT return formed in the e‑invoicing system, in line with the Law on Electronic Invoicing.

This ex officio VAT return contains only data on output VAT, taken from the preliminary return.

Temporary tax assessments become final after 3 years

A time limit of three years is introduced for temporary tax assessments.

If, within three years from the issuance of a temporary assessment, the Tax Administration does not issue a final assessment in that case, the tax liability determined in the temporary assessment is deemed final.

RFPIO certificate as basis for refund of overpaid social security contributions

The LTPPA is aligned with regulations on compulsory social security contributions.

The right to a refund of contributions paid above the maximum annual base is now proven by an RFPIO certificate, which becomes the key document for obtaining the refund.

Tax returns filed ex officio and based on audit findings

The Tax Administration will file tax returns on behalf of the taxpayer:

• Ex officio, based on official records; and
• Based on audit findings, using facts established during the tax audit.

A tax return based on audit findings is filed on the date of the decision that establishes an unreported tax liability. Taxpayers no longer have an obligation to file a tax return themselves following the Tax Administration’s audit findings – this is now done by the Tax Administration.

Extension of deadline for filing tax return and due date of tax assessed in a return with extended deadline

The rules for extending the deadline for filing a tax return are clarified:

• A request for extension must be filed separately for each type of tax and each tax period.
• If the Tax Administration approves the extension, the extension applies both to the filing deadline and to the due date of the tax liability from that return.
• If the taxpayer files the return after the extended deadline, the tax becomes due within the period prescribed by the specific tax law.

In practice, when an extension is approved, interest is not calculated for the period from the original due date to the date of filing, provided the return is filed within the approved extended deadline.

If the return is filed after the approved extended deadline, interest is calculated from the original due date until the date the liability is paid.

Automatic settlement of excise duties within the same return

As of 1 February 2027, automatic internal offsetting of excise duties is introduced, without a taxpayer’s request.

The Tax Administration will ex officio:

• Settle due and unpaid excise liabilities on one excise payment account from overpayments on another excise payment account,
• Provided that both excise liabilities are shown in the same tax return and for the same calculation period.

If an overpayment remains after this, it is further used to settle other due and unpaid excise liabilities in the prescribed order of settlement, again without a taxpayer’s request.

Interest calculation on tax assessed in a tax audit

Interest in the period of delay on the amount of newly assessed tax in an audit, from the due date of the tax liability until the date of payment, is calculated independently of changes in the balance on the tax income account during that period.

In other words, the fact that the taxpayer was in an overpayment position on the same tax account during the interest calculation period has no impact on the base used to calculate interest on the liability determined in the audit.

Suspension of the statute of limitations – now also for taxpayer rights

The rules on suspension of the statute of limitations no longer apply only to the assessment and collection of taxes and ancillary charges, but also cover:

• The right to a refund,
• Use of a tax credit,
• The right to refund and reimbursement, and
• Settlement of due tax liabilities through offsetting (rebooking).

In practice, the period of suspension will not be counted in the statute of limitations period not only for the Tax Administration’s rights to assess and collect, but also for the taxpayer’s financial rights.

Stricter sanctions for abuse of electronic fiscalization (QR code)

A sanction of prohibition to perform business activities for one year is introduced, which is imposed immediately, in cases of abuse of the electronic fiscalization system via the QR code on the receipt.

A violation occurs when a receipt is issued with a QR code for which verification shows that it:

• Was not generated through the Tax Administration’s electronic fiscalization system;
• Does not lead to the Tax Administration’s portal;
• Leads to a fiscal receipt that does not correspond to the actual transaction (different amount, date, items or different taxpayer); or
• Represents a document later modified, combined or technically created.