In this episode, we talk about new regulations for Serbia with our Senior Account Manager Tuğçe Özgün and Account Manager Merve Koç. We tried to discuss everything there is to know about Serbia’s e-Invoicing model.
1. Will e-invoicing come into effect for all taxpayers at the same time or will there be a gradual implementation?
The introduction of the electronic invoicing is going to be rolled out in three stages:
- G2G and B2G mandate transactions will be first and will become obligatory from May 2022.
- This will then be followed by G2B transactions from July 2022.
- Finally, by the beginning of January 2023, B2B e-invoices will become mandatory, and this will conclude the phased introduction of obligatory e-invoicing.
2. What are the main ways of generating, transmitting, and receiving electronic invoices according to the new regulation?
There are going to be two main ways: you can either submit e-invoices manually through the e-invoicing portal or directly from your ERP system (such as SAP) using a dedicated API provided by the Serbian tax authorities.
3. What format and technical requirements will the electronic invoices have?
E-invoices will have to be issued in XML format in line with the UBL 2.1 standard.
The content of the invoices themselves is going to be quite demanding, and numerous fields in the XML file (such as seller and buyer data, product data on goods, detailed VAT data, and payment instruction) will have to be included in the invoices.
4. Is an electronic signature requested before the transmission of the invoices?
Yes, the electronic invoices will have to be signed electronically before they are submitted to the tax authorities.
5. What are the legal penalties for not complying with the regulation of electronic invoicing?
Non-compliance with the electronic invoicing requirement is subject to penalties of up to 2 million Serbian dinars (around 17,000 Euro).
6. Is it mandatory to archive the electronic invoices?
Electronic invoices issued or received by public sector entities are stored permanently in the electronic invoicing system. Those issued and received by private sector entities are stored for up to 10 years after issue.
7. Are non-established companies that are registered in Serbia for VAT only obliged to be linked to the e-faktura system and validate their invoices issued to customers?
Non-established companies will not be obliged to issue electronic invoices, but they will be able to voluntarily apply to use SEF.
8. Does the obligation apply to companies that issue an invoices for goods that are exported?
In the case of cross-border transactions, they do not need to be entered into the system if they are issued by a VAT-exempt entity. However, this doesn’t apply to the ones who are voluntarily signed up for SEF.
9. What are the main controls performed by Serbian Tax Authorities upon receipt of the e-invoices?
The tax authorities perform both technical checks to make sure that all the requested XML elements are present in the file and that financial data (i.e. tax amounts) are correct.
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