Serbia’s Ministry of Finance has amended its VAT Rulebook, introducing a revised VAT return and preliminary return process, updated VAT record-keeping requirements, and changes to VAT refund and refaction forms, effective from January 2027.
Serbia’s Ministry of Finance has adopted amendments to the Rulebook on Value Added Tax (VAT), published in Official Gazette No. 71/2026. The amendments will apply from the tax period beginning in January 2027, covering the January–March 2027 quarter.
The Rulebook on Value Added Tax in Serbia provides a comprehensive legal framework for the practical application of VAT laws. It defines critical criteria for distinguishing taxable transactions, such as distinguishing between leasing agreements and the supply of goods. The framework sets rules for business samples, promotional gifts, asset transfers, reduced-rate goods and services, foreign tax representation, and tax-base calculations and adjustments.
The key changes are:
Preliminary VAT return and accompanying forms
SEF integration and generation: The preliminary VAT return represents an automated dataset of taxable supplies, imports, and VAT transactions compiled within the Electronic Invoicing System (SEF) based on data available in SEF on the day preceding generation. Taxpayers trigger the generation of this preliminary return in SEF within the statutory filing window for the given tax period.
Structure of the return: The preliminary return comprises three specific forms:
- Form PPP PDV: The primary preliminary VAT return form summarising output tax, input tax, and final tax liability.
- Form Annex 1: Captures base amounts, consideration, and VAT derived directly from electronic invoices and electronic VAT records in SEF.
- Form Annex 2: Captures data on supplies of equipment and facilities used for business activities, as well as investments made in such operational facilities.
Data Workflow
Form Annex 1 is automatically populated with data from SEF via the taxpayer’s e-invoices and electronic VAT records. Conversely, Form Annex 2 requires manual data entry by the taxpayer for equipment supplies, operational facilities, and facility investments. Once both annexes are finalised, their data automatically feeds into the Form PPP PDV. Generating a new preliminary return automatically cancels any previously generated preliminary return for that tax period before submission.
New VAT return form (Form PP PDV) and required attachments
The Rulebook introduces a revised VAT return form (Form PP PDV), featuring a 9-part structure aligned with the data categories of the preliminary return. Taxpayers submitting a regular, timely VAT return must attach the preliminary VAT return generated in SEF as the primary attachment, along with the following mandatory forms:
- Form Annex 2: Reports business equipment, operational facilities, and facility investments.
- Form Annex 3: Provides annual details of specified purchases from non-VAT-registered sellers.
- Form Annex 4: Reports VAT corrections relating to previous tax periods.
Amending VAT records
The rules governing the format, content, and keeping of VAT records (Articles 209–237а) are restructured to mirror the fields of the new PP PDV form and preliminary return:
- Tracking internal invoices: VAT records must explicitly record data on internal invoices generated for reverse-charge tax liability or adjustments.
- General vs. separate VAT records: General VAT record data groups are being restructured to align with the new VAT return form, while records for travel agencies and transactions involving second-hand goods, works of art, collectors’ items, and antiques must be maintained separately under their respective special VAT schemes.
- Advance payments and free-of-charge supplies: Advance payments must be tracked in separate data groups, whereas supplies made free of charge are recorded together with supplies made for consideration under their respective transaction categories.
- Tax exemptions: Data regarding supplies of goods and services exempt from VAT (both with and without input tax deduction rights) must be kept separately, grouped by the specific statutory provision of the VAT Law granting the exemption.
Amendments to forms for VAT refunds and refactions
The Rulebook updates the official forms used to exercise rights to VAT refunds and refactions. The revised forms include:
- Form REF 1: Application for VAT refaction by foreign taxpayers.
- Form REF 2: Application for VAT refaction by humanitarian organisations.
- Form REF 3: Application for VAT refaction by traditional churches and religious communities.
- Form REF 4: Application for VAT refaction by diplomatic/consular missions and international organisations.
- Form RFN: Application for VAT refund by buyers of their first apartment.