The Serbian Ministry of Finance announced the law of electronic invoicing (Official Gazette of RS, No. 44/2021 and 129/2021) in 2021, and completed the public consultation within the year.
The new national e-Invoicing system is named Sistem e-Faktura, which is an example of a clearance model, as used in Italy.
Scope of the e-Invoicing system
The e-Invoicing law covers the generation, transition, receipt, processing, and archiving of electronic invoices. Both parties will be under obligation for each transaction, including public and private sector entities (B2G and G2B), transactions between taxpayers (B2B), and also those between public authorities (G2G).
Below you can see the groups that are responsible for the law:
- Public sector entities
- Entities in the private sector that are liable for VAT,
- VAT representatives for foreign companies
Timeline of implementation
The scope of the new system will expand gradually, and the timeline will be completed in three phases:
Phase 1. Private sector entities are mandated to issue e-Invoices to public authorities, while the public authorities are compelled to receive and archive e-documents (B2G transactions). Additionally, public authorities are also obligated to send and receive e-Invoices for any business conducted with other public authorities (G2G transactions) from 1 May 2022.
Phase 2. Public authorities are obligated to issue and send e-Invoices to private sector entities (G2B transactions). Private sector entities will be obliged to receive and archive e-Invoices from 1 July 2022.
Phase 3. Full implementation is complete and electronic invoices become mandatory for the private sector in mutual transactions (B2B transactions) from 1 January 2023.
The test environment has effectively been working since 2021. Any business whose obligation deadline does not come to issue e-Invoices on a voluntary basis, on the condition that the company either pays income tax on self-employed work or is liable for corporation tax.
Technical details of the new e-Invoice system
An electronic invoice must be issued and received in line with the Standards EN 16931-3-2, which is in XML format.
Electronic invoices may be transmitted in several ways. Firstly, transmission can be done directly to the government platform. However, only manual submission can be uploaded online. Secondly, e-Invoices can be submitted to the government portal via a service provider, which is mentioned as intermediaries in the law. Furthermore, the Ministry of Finance published a rulebook to inform interested parties about the requirement of being an intermediary. The approval of the ministry responsible for finance is required.
Electronic invoices generated or received by public authorities must be permanently archived in the government’s e-Invoice system. On the other hand, the electronic invoices generated and transmitted by private sector entities must be stored for 10 years as of the end of the year in which the electronic invoice was issued in the electronic invoices system or in the service provider’s system (the intermediary’s system).
Fines for non-compliance e-Invoice
Fines are changing between legal entities and their responsible representative. For instance, if the tax authority detects that a legal entity is not complying with the published standards or dates, fines range from EUR 1,701 to EUR 17,011, and the representative range starts from EUR 425 to RSD EUR 1,276.
How can SNI help you?
SNI’s Serbia e-Invoicing add-on solution is an end-to-end solution. That means retrieving data from SAP, data mapping, processing, and communication with tax authorities can be performed under a single SAP add-on. With our SNI add-on solution, within your SAP, end users will be able to extract the financial data and convert it to the XML file simply and automatically, which the key user can monitor in the user-friendly SNI cockpit. End users can also send those files automatically to the Serbian tax authority, that is Poreska Uprava, via SNI connector or their own servers. The files are then assessed and, once validated, transmitted to the recipient.
