Dear business partners,
We would like to inform you that on January 01,2024 the NEW Rulebook on Amendments to the Rulebook on Electronic Invoicing entered into force.
You can find the same in the attachment, and we would like to mention the most important changes:
The rules have been specified and partially changed regarding the obligation to electronically record the calculated VAT in the SEF (System of electronic invoices), especially important is the shortened deadline for VAT registration with application start from January 01,2024;
introduction of a new obligation of electronic recording of VAT calculated in the previous phase of turnover, i.e. payment when importing goods in the SEF with application start after August 31,2024.;
In our opinion, the shortened deadline of 10 days after the end of the tax period refers to the calculation of VAT starting from the tax period that begins on January 01, 2024.
Which means that monthly VAT payers will calculate January VAT in the SEF no later than February 10, 2024, and quarterly taxpayers for Q1-2024 until April 10, 2024.
A taxpayer who is a tax debtor in accordance with Article 10 of the Value Added Tax Law (“ZPDV”) (the most frequently received services in the field of construction over RSD 500,000.00 and foreign services) is obliged to prepare an internal invoice within 10 days in accordance with Article 196 of the Rulebook on VAT for all the mentioned services and records the same in the Individual records in the SEF, and submits to us the Internal invoice and the accompanying document in the attachment (Contract with the supplier on the basis of which the Internal invoice was drawn up, the invoice received from the supplier, or a bank statement where the advance payment was recorded)
The provisions of Article 4 paragraph 6 of the Law define that if there is a change that has an impact on the recording of calculated VAT, we can make the correction by the deadline for submitting the tax return for the PERIOD IN WHICH THAT CHANGE OCCURRED, IN THIS CASE THE CHANGE OCCURED IN FEBRUARY, SO THE DEADLINE FOR CORRECTION IS March 15,2024 at the latest for VAT correction 01/2024.
We especially emphasize that this deadline is given for the correction of an error or a change that has an impact on the recording of VAT calculations, but not for failure to record VAT!
In accordance with Article 21 of the Rulebook, if the invoice, advance invoice and document on the increase is not issued within 10 days after the end of the tax period for which the tax liability arose in accordance with the VAT Law, the calculated VAT amount is recorded in the individual VAT record for that tax period. and the type of document that should have been issued is specified as the document type, and “0” (zero) is specified as the document number.
If, after the expiration of this period, an electronic invoice from paragraph 1 has been issued or there has been another change that has an impact on the electronic recording of the calculated VAT for a certain tax period, in the VAT summary record for the tax period to which the electronic invoice refers or the tax period for which electronic recording of VAT calculation is performed, electronic recording of VAT calculation is corrected.
The correction of the electronic recording of the VAT calculation from paragraph 2 is made within the deadline for submitting the tax return for the tax period in which the electronic invoice was issued or another change occurred by recording the amount of VAT from paragraph 1 in the field in which the data on the VAT reduction is reported .