Serbia has adopted a broad set of VAT law amendments that reshape reporting, invoicing-related adjustments, and several timing rules relevant to day-to-day VAT operations. While many provisions are scheduled to apply from 1 April 2026, certain rules take effect earlier or later. The most significant operational shift is the stronger alignment between VAT outcomes and the electronic invoicing framework (SEF) especially through expanded requirements for internal invoices.
1. Timeline and effective dates
Serbia adopted the amendments in December 2025. The changes generally apply from 1 April 2026, while certain provisions have a different start date. This staggered approach creates a short implementation window for 2026 process changes and a longer runway for the 2027 reporting modernization.
2. VAT reporting modernization: what moves to 2027
2.1. Pre-filled VAT returns postponed
A planned “pre-filled” VAT return model has been deferred to 2027. Practically, this gives businesses additional time to improve the quality and consistency of the transactional data that will ultimately feed the VAT reporting layer.
2.2. Revised approach to correcting prior-period errors
From 2027, the framework supports disclosing certain prior-period understatements/overstatements through the current VAT return rather than relying exclusively on amended returns. This reduces administrative friction, but it increases the need for documented controls and audit trails around how corrections are identified, approved, and posted.
3. Supply timing and periodic billing: clearer tax point rules
3.1. Periodic invoicing for utilities
For periodic supplies such as water, electricity, gas, and heating/cooling energy for final consumption, the VAT “tax point” is tied to the last day of the invoicing period, with limits on how long that period can be. This impacts how ERP systems determine tax dates and how billing calendars align with VAT periods.
4. Credit notes, tax base reductions, and cancellations: tighter discipline
4.1. Mandatory documentation for tax base decreases
When the VAT base decreases after an invoice is issued, the amendments reinforce the need for formal documentation (commonly via credit notes) and more prescriptive timing for recognizing the adjustment. The operational takeaway is that VAT decreases are increasingly conditioned on completing the required steps within defined filing and post-period timelines.
4.2. Invoice cancellation mechanics
The amendments also tighten the rules and sequencing around invoice cancellations and related VAT adjustments, including conditions that may involve replacement invoices and evidence supporting the VAT position taken by both supplier and recipient. This raises the importance of standardized cancellation workflows between accounting entries and invoice status.
5. E-invoicing update (SEF): internal invoices become a central compliance object
5.1. Expanded scenarios requiring internal invoices
Internal invoices are no longer limited to a narrow set of reverse-charge situations. The amended rules broaden and clarify when internal invoices must be prepared, including scenarios involving:
- reverse charge obligations,
- changes to the tax base (increases/decreases),
- advances and adjustments to advances.
This expansion increases internal invoicing volume and makes internal invoices a more material component of VAT governance.
5.2. Internal invoices must be generated within SEF (for SEF users)
For businesses operating within the electronic invoicing framework, internal invoices are expected to be created inside the SEF environment, not only as back-office accounting artifacts.
5.3. Cancellations and corrections for internal invoices
Where internal invoices are cancelled or corrected, the amendments introduce more explicit expectations around reversing or adjusting related VAT effects. This means internal invoices need the same level of lifecycle governance as “external” invoices creation, cancellation, and linkage to VAT outcomes.
6. Closing perspective
Overall, Serbia’s VAT amendments signal a shift toward compliance that is enforced through digitally executed invoicing processes, not only through post-fact reporting. The strengthened role of SEF-based internal invoicing is the most consequential update for e-invoicing leaders: it changes what must be produced, where it must be produced, and how it must be controlled.
