The amendments to the Law on Tax Procedure and Tax Administration were published in the “Official Gazette of the Republic of Serbia”, No. 80 of 31 August 2026. Although a significant part of the amendments concerns the organisation and operation of the Tax Administration, several changes have a direct practical impact on taxpayers:
- The Tax Administration may file a tax return on behalf of the taxpayer – both ex officio and on the basis of the findings of a tax audit.
- Special rule for the annual personal income tax – if a taxpayer fails to file the return within the prescribed deadline, the Tax Administration will file it ex officio.
- VAT return filed ex officio – if a taxpayer fails to file a VAT return within the prescribed deadline, the Tax Administration will prepare and file it on the basis of a preliminary tax return generated in the electronic invoicing system. Such return contains only the data relating to the calculated VAT taken from the system.
- Extension of the tax return filing deadline also extends the tax payment due date –if the return is not filed within the extended deadline either, the due date prescribed by the relevant special law will apply.
- No longer a limit on the number of amended tax returns – the limitation under which an amended tax return could be filed no more than twice has been removed. This amendment also applies to tax returns filed before the new law enters into force.
- A provisional tax assessment may become final – if the Tax Administration does not issue a decision replacing the provisional tax assessment within three years, the tax liability determined by the provisional assessment will be deemed finally assessed.
- Interest on an established difference in tax liability is calculated from the day following the due date of the tax liability until the date of payment.
- Particularly strict measure in the area of fiscalisation – issuing an invoice containing a QR code that was not generated through the Tax Administration’s electronic fiscalisation system, does not lead to the Tax Administration’s portal, or leads to a fiscal receipt that does not correspond to the actual recorded transaction, may result in a prohibition on carrying out business activities for a period of one year. This measure is imposed immediately.
- Settlement of excise tax liabilities – the Tax Administration will, ex officio, settle due and unpaid liabilities under one excise tax payment account from an overpayment recorded under another account, subject to the conditions prescribed by law. This provision will apply from 1 February 2027.
The new provisions further demonstrate a trend towards a more automated tax system and stricter enforcement of tax compliance. For taxpayers, this means that the timely filing of tax returns, monitoring data in the electronic invoicing system and ensuring the accuracy of fiscal receipts are becoming even more important, particularly given that certain omissions may no longer result merely in the subsequent assessment of a tax liability, but may also lead directly to significant sanctions.
For additional information or consultations, the Tasić & Partners team is at your disposal.