Amendments to the VAT Rulebook and the Electronic Invoicing Rulebook

The amendments to the VAT Rulebook and the Electronic Invoicing Rulebook are comprehensive and extensive, and shall apply beginning with the April tax period, i.e. April–June 2026. In order to provide you with a general overview and help you understand the scope of these changes, we will highlight some of the most significant ones:

• An obligation is introduced to issue internal invoices within the SEF system in the form of individual records;
• The types of records within SEF are clarified, specifying three categories: aggregate VAT records, individual VAT record – internal invoice and individual VAT records related to supplieswith possible statuses: recorded, corrected, and cancelled;
• It is specifically prescribed when a SEF user is required to correct previously submitted records and when to cancel them.

Clarification of rules on determining the tax base by estimation in cases where the amount of consideration is not known at the time the tax liability arises – if the estimated tax base differs from the tax base at the moment the tax liability arises, it is considered that a change in the tax base has occurred in accordance with Article 21 of the VAT Law, and such change is made for the tax period in which the amount of the tax base became known.

• Clarification of situations in which there is an obligation to issue a credit note, and cases where such obligation does not exist, e.g. where the person liable for VAT is the recipient of goods and services and where the supply is VAT exempt;
• Conditions for VAT reduction are prescribed where the person liable for VAT is the recipient of goods and services with the right to deduct input VAT – the reduction of output VAT is not conditional upon possession of a document confirming the decrease in consideration, whereas in cases where the recipient does not have the right to deduct input VAT, such reduction is conditional upon possession of such a document;
• It is prescribed that, in the case of a subsequent reduction of the tax base, a VAT payer may reduce output VAT for a given tax period if the prescribed conditions are met no later than the day preceding the submission of the tax return for that period, and at the latest by the 10th day of the calendar month following that tax period, rather than exclusively in the period when all conditions are met;
• A reduction of the tax base due to a subsequent discount occurs on the date when the conditions for granting the discount are met in accordance with the contract – – issuance of a credit note is not a prerequisite;
• An increase of the tax base due to subsequent charging of costs related to the supply occurs on the date of issuance of the document by which such costs are charged;
• Clarification that, in the case of an increase of the tax base, there is an obligation to issue an internal invoice where the taxpayer is the recipient of goods and services

• In case of a subsequent reduction of the tax base for a taxable supplies where the supplier is the taxpayer, including reduction of a advance payments, the recipient who has exercised the right to deduct input VAT is required to reduce the input VAT based on a credit note issued in accordance with the VAT Law, rather than merely based on the fact that the tax base has been decreased;
• Adjustment of input tax deduction due to a change in the tax base
• The form, content, and method of submission of the recipient’s notification regarding input VAT are prescribed in detail;
• Defined sequence of actions for proper compliance – first, the VAT payer who supplied goods and services issues a credit note, and then the VAT payer who is the recipient issues a notification regarding input VAT;
• A uniform general rule is introduced whereby the return of goods on any grounds no longer constitutes a new supply but rather results in a change in the tax base;
• Further regulation of advance invoices – for example, it is specified that an advance invoice does not need to be issued if the advance payment is made on the same day as the supply, and that a VAT payer receiving an advance payment (who is not the taxpayer on that basis) is still obliged to issue an invoice;

Significant changes regarding internal invoices and invoice cancellations – e.g. it is specified for which tax period a taxpayer must adjust input VAT deduction in case of document cancellation, and a new obligation is introduced to adjust input VAT deduction also in the case of cancellation of an internal invoice issued by the recipient acting as the taxpayer, not only based on invoices and other documents of the previous participant in the supply chain.

Thank you for your attention!
For all questions you might have, we are at your disposal.
IB Interbilanz Consulting
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office@interbilanz.rs